March 3, 2025 • 34 mins
An estimated 5% of foster youth qualify for Social Security benefits, but in many states, child welfare agencies use these funds to help cover the cost of care. In 2018 alone, agencies in 49 states and Washington, D.C., received at least $165 million in benefits intended for foster youth.
In this episode, Shoshana Weissmann interviews Maureen Flatley, subject matter expert in child welfare and child exploitation. They discuss how these funds are managed, the policies guiding their use, and the ongoing conversations about their impact on foster youth and the child welfare system.
In this episode, Shoshana Weissmann interviews Maureen Flatley, subject matter expert in child welfare and child exploitation. They discuss how these funds are managed, the policies guiding their use, and the ongoing conversations about their impact on foster youth and the child welfare system.
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Episode Transcript
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Speaker 1 (00:02):
Welcome to the Regulatory Transparency Projects Fourth Branch podcast series.
All expressions of opinion are those of the speaker.
Speaker 2 (00:18):
Welcome to the Regulatory Transparency Project's Fourth Branch podcast. I'm
Sarah Bankson, Deputy Director of RTP. Today we're happy to
host two experts as they discuss the issue of state
child welfare agencies using the social security benefits of foster
care children. Maureen Flatley is a subject matter expert in
child welfare and child exploitation, with a particular expertise in
(00:41):
government reform and oversight. We're also joined by Shoshana Weissman,
director of Digital Media and Technology and Innovation Fellow at
Our Street Institute. Thank you both for being with us today.
Our listeners can read more about our speakers at regproject
dot org. With that, I'll hand it over to you
Shashana too.
Speaker 3 (01:01):
Thank you so much.
Speaker 4 (01:02):
I'm so excited to talk about this today. So to
start from my work in technology policy and looking into
the identity theft issues. A lot of age verification proposals,
you know when you have to upload government ID, your
social security number, stuff like that to different platforms. There's
real implications for child identity theft, which is a really
(01:24):
really big problem. But when I was diving in here,
I found something that I couldn't believe, that a lot
of state governments steal money from orphans. So I'm going
to read a piece, a short paragraph from Imprint News
that did a really, really great piece on this, and
then we'll dive in and figure out how the heck
this happened. So Imprint News reported that nationwide, an estimated
(01:46):
five percent of all children in youth and foster care
qualify for Social Security Administration, Disability and survivor benefits, but
when they receive them, child welfare agencies often intercept those
payments that can amount to more than nine hundred dollars
a month. An investigation by the Marshall Project and the
National Public Radio estimated that in twenty eighteen alone, child
(02:07):
welfare agencies in forty nine states and the District of
Columbia seized at least one hundred and sixty five million
dollars owed to foster youth and use the money to
pay for the cost of their placements in the child
welfare system. Thankfully, since this report, Arizona, Colorado, New Hampshire,
and Washington, DC passed some comprehensive reforms to stop these practices,
(02:31):
and a lot of other states stepped in for different
levels of reforms. But I think, to start, Maureen, what
the heck is happening here? Why are states stealing money
from literal orphans?
Speaker 5 (02:43):
Well, I think the simple answer is because they can.
And I think it's fair to say that this is
a practice that obviously started a long time ago, and
it was just something that came about over a over
a period of time as states struggled to underwrite the
cost of child welfare programs. And I think it may
(03:07):
have it was probably a function of what we call
revenue maximization, where when a child enters care, states basically
do an inventory of benefits that that child may be
eligible for. So if the child has severe special needs,
or educational deficits, or other kinds of extraordinary requirements, they
(03:31):
look for ways to pay for those additional services. I
first discovered this many many years ago when it was
clear to me that a particular county in California was
actually issuing multiple Social Security numbers to the same kids
so that they could make multiple title for eclaims to
the Feds. But the social Security piece of it surface later.
(03:57):
And the thing that I really want to emphasize is
that the states are capturing this money without the permission
of the children's parents, who are sort of, in many instances,
sort of the predicate beneficiary. They are often not even
using the money for the kid's care. It goes into
(04:19):
a general fund. One of the most pernicious aspects of
this is that in many states there's a significant number
of children in the system that the states can't even locate,
and yet they're collecting money for those kids. So it's
(04:39):
a practice that's going on for a long time. There
have been a number of efforts to stop it in
Congress because you know, obviously, although child welfare is viewed
as a state law issue, there's a huge amount of
federal money that flows into the state systems. And the
states actually opposed the suspension of this practice, and incredibly
(05:00):
Congress went along with it. So it's a long standing
practice and one that was sort of ginned up to other,
you know, to bolster the funding that they already received
from the Feds in the states.
Speaker 4 (05:16):
So I love that you brought up so many things
I really want to dive into. I think I don't
even know where to start. I think we'll start with maybe,
so the state agencies were doing child identity theft on
behalf of themselves to steal money from kids, Like that's
something that you start present.
Speaker 5 (05:33):
In any other context, several aspects of this would probably
be considered criminal behavior. So in other words, they're applying
for federal benefits. I'll give you an example. A family
lost custody of their child. Mom and dad were both
in the grips of the mental health crisis. They were
(05:55):
both receiving SSDI in the state that had custody of
the child realized it, and without their permission or anyone's permission,
they tapped into eligibility for the child. So the child
started the child started receiving significant benefits. Of course, as
far as we know, he never saw any of that money.
(06:17):
In any other context, I'm fairly certain that would be
considered theft. Then you have the right you're stealing money from.
Then you have the issue of the fact that these
children do not have trustees. And so if this were
say senior citizens, and most states have elder care laws
(06:37):
that are even more aggressive than their child welfare laws,
these kids should have each have a trustee who is
their representative paye who can maintain control over the funds
and keep the fund sequestered for that child. For instance,
let's say a child has significant unmet medical needs or
psychiatric needs as a result of whatever disability the parent had.
(07:03):
The money should be put in a trust so that
when that child needs extraordinary services, the trust can then
offset the cost of those services. What happens now is
that there's no trust of any kind. The child often
receives zero services. As I said before, sometimes the state
(07:23):
doesn't even know where the child is, and the state
is using that money to build baseball fields and buy
police guards. So they are really kind of two problems here.
At the front end, you have what you and I
have certainly looked at together as straight up identity theft.
This is not the person who is eligible for the services.
(07:46):
If it's a child, there's no armslength third party guardian
or trustee, And then the money is not being used
for the purpose that it was designed. So really what
we have here is kind of a double edge scam
that the states have continued without really any serious pushback
(08:10):
from Congress. I mean, there have been a couple of
efforts on the part of Congress as you and I
have talked about to suspend this practice, but nothing that
ever amounted too much because the states came forward and said, no, no,
we really need that money. And so what ends up
happening is that you have twenty two thousand kids a
(08:31):
year age out of the foster care system, completely destitute,
most of the medically neglected, educationally neglected, dentally neglected, psychologically neglected.
They can't afford to run an apartment or get a car.
It's really astounding that this has been permitted to continue.
Speaker 3 (08:54):
Oh definitely.
Speaker 4 (08:55):
When I learned about this through you and through the
research here, I was just so astonished that this could
go on. And there's a couple of good government principles
that are being violated here too. Like one is that
and I'm sure sure you've heard of this one too,
that it's just a good idea that when government uses
taxes to pay for something, it should only go to
that one thing, and it shouldn't be in a general fund.
(09:16):
That you want a good means sense to fit where
you can have it because it ties resources to what
they're supposed to go for, and obviously that's not happening here.
And another one is you know, generally I'm worried about
the federal government and being involved in state affairs.
Speaker 3 (09:29):
This is not one of those cases. But in part
because the.
Speaker 4 (09:32):
Social Security funds are supposed to go to the parents,
to the families. That's you know, that's why it's there,
But the money is being totally misused, like this is
not what the money is there for. So I don't
have an issue with the federal government setting and like,
I'm glad states are and that's great, but I'm not
against additional protections to make sure this doesn't happen.
Speaker 3 (09:51):
And another thing too, is.
Speaker 4 (09:52):
Just you know, I'm someone who dons to be pretty
skeptical of government, Like I tend to question a lot,
but I never would have ever imagined that states and
the government would see kids who are in these positions
and abuse their financial resources like this, Like this is
something that's just so far beyond my imagination that even
(10:15):
when I've talked to other people who are very skeptical
of government, they're still like, what the heck, Like how
could this even happen? But I think you bring up
a really good way to round out that not only
is it happening, like to some degree, it's happening a lot,
and it's happening in ridiculous ways, like you know, applying
for multiple Social Security numbers so they can get more
benefits and still you know, send it to the state.
(10:38):
One thing I want to dig in with you a
little bit more on is that I think one thing
that makes it so agreed just is what you started
talking about, where where basically when kids age out of
foster care, they often end up homeless, they have really
poor outcomes. They've just had hard lives and a lot
of difficulties, which makes it all worse. But from you've
done a lot a lot of work over the years
(11:00):
with foster youth, But have you seen how this has
affected them and cases maybe where where they could have
had better outcomes if they had the resources that they
properly were supposed to have.
Speaker 5 (11:15):
I mean, this has been one of the banes of
my professional life for a couple of decades now, because
I see and I was a foster parent in DC
for ten years, and so I would also say that
I've seen this up close and personal in a very
different way. But what is an outrage to me? Well,
(11:38):
first of all, let's go back to what you said
about federal versus state. You know, everybody views child welfare
as a state law issue. However, I would posit that
dating back to the orphan trains in the eighteen fifties,
there has been a fundamentally interstate component to child welfare
that was then really kind of cemented when federal dollar
(12:00):
started blowing to the states a child. The Beast Prevention
of Dreaming Act was created in nineteen seventy four, and
that kind of codified all this stuff from a federal perspective,
and the states had to comply with that to get
the federal part of their share. So stagehild welfare is
funded by a matrix of both federal and state funds
and of course now the Social Security money. So while
(12:25):
I'm not a big government person, and while I certainly
think that it's interesting in this case that the states
have stepped up to mitigate this practice before the Feds
actually have, there is some movement in Congress. I do
think that it might be the moment. You know, there's
always a moment for issues when they finally ripe inadequately
and people start to take them seriously. And I think
(12:47):
we are maybe at that point in Congress, but at
the end of the day, this is a Dickensian scenario
because you know, as you know, I've known probably thousands
of funster youth at this point, and what they would
all say is that, you know, there was nothing good
about being in foster care. They didn't get the things
(13:07):
they needed. I can't think of a single foster youth
I've seen age out that didn't have some dire financial
circumstances that was a victim of identity theft. You and
I talk about this all the time, that the incidence
of identity theft of kids in foster care is dramatically
higher than the general population because so many people handle
(13:30):
their identifying information, And looking at this social security scam
is like the hyper example of that. You know, here
these folks have access to their social Security numbers, but
there isn't even the patina of effort to create a
third party paid to create a guardianship, to create any
(13:50):
kind of trust situation. I've consulted over the years with
some of the world's leading experts on trust in estate law,
and they all consider this to be an illegal taking
of these benefits for the kids. So at the end
of the day, first of all, many of the kids
don't even know this is going on. They have no
(14:13):
idea that the state is collecting, you know, nine hundred
to twelve hundred dollars a month in their names and
they're you know, not going to the dentist, they don't
have glasses, they're in desperate need of educational support. None
of that is happening, okay, even in sort of the
best case scenario. So ultimately, when you look at the
(14:38):
way that these kids are treated, it's not much different
from the chatnel that was the orphan trains, where kids
were basically just dropped off in the middle of nowhere.
The other thing is that in addition to the twenty
two thousand kids who age out every year, and that
number has remained consistent since the nineteen late nineteen nineties
(15:01):
when we did the Adoption and Save Families Act, which
was a massive overhaul of child welfare policy passed in
a very bipartisan way actually, But then you also have
roughly one in nine adoptions from foster care fail those
kids re enter the system. Then you have another component
(15:23):
of kids who are adopted internationally who are also going
into foster care. So the system has become this kind
of basket of failure. I mean, I don't think it's
ever really been very successful, and I would, you know,
I would admit and argue that the States have a
tough job. But at the same time, if they were
(15:45):
running a hospital system and this percentage of patients were
dying or they were misappropriating, say, patients insurance money, I
can assure you that no one would tolerated. And so
the fact that we've allowed this, which was designed to
care for literally the most vulnerable population of children in
(16:08):
this country, to operate so carelessly and so exploitably, well,
you know, it's like I always tay to Jhanna, this
isn't necessarily Congress's fault. This is our fault, because we've
all kind of let this happen and it really needs
to stop.
Speaker 3 (16:28):
Oh definitely.
Speaker 4 (16:28):
I was actually talking with a friend in the South
who was telling me that he had adopted a few
kids and some of them have severe disabilities, and he
was a little bit surprised that he wasn't getting some
benefits along with it, just to help with their care.
And I told him he should go look into this
because I wonder if even when they get adopted, that
this is still happening and I wouldn't be surprised if
(16:49):
that's still the case, and so astonishing that we've But
you're right with astonishing we've let this happen and that
states haven't fixed this issue. But I'd also like to
get into I know, one thing you talk about that
always stuns me too. So much of this is so
new to me, and I know that you're used to it,
and I know that you know it's surprising, but it's
(17:11):
stunning to me that not only are we losing foster
kids at an alarming rate in the system, that they
just disappear and we might never find them again or
know what happened to them, but that even when that's happening,
the government is still trying to find ways to milk
them for money. How you know, isn't I mean there
has to be a level of realizing something is horribly
(17:33):
wrong in that case. But does government just see it
as like, oh, well, we need the money. Is that
all it comes down to you?
Speaker 5 (17:38):
Pretty much? Yeah? I mean, you know, I use the
example of there was a little girl in Florida called
Willia Wilson who was in foster care in the system.
She was adopted at a relatively young age by a
single mom, and the benefits were flowing adoption, subsidy payments,
whatever benefits she was eligible for. And after a period
(18:01):
of time, the neighbors realized that no one was seeing
the child. She wasn't in school, she wasn't playing in
the yard, and so an investigation was triggered and people
realized that she had basically been missing for five years,
but the parent was continuing to collect subsidy payments. This
(18:21):
triggered This triggered an audit in Florida looking to see
what other kids they did couldn't find, and this happened
about fifteen years ago. I can't remember the exact number,
but let's say it was about twenty percent of kids
in the system that the state couldn't even locate for
a variety of reasons. Some of the kids were dead,
(18:44):
some of the kids had left the system, some of
the kids were runaways, and really his case, the belief
was that she had been murdered. I don't believe that
a body was ever discovered. But you know, we see
this all the time. You see this all the time
in fatality cases where kids are literally deceased and yet
the benefits still flow. So now the states have taken
(19:07):
the attitude. And I don't mean to necessarily bash the
states in general, because I think it's sort of a
child welfare agency problem, not a whole state problem. But
they're just leave us alone. This is a hard job,
you know. I live in Massachusetts now and we've had
(19:27):
an alarming number of child fatalities in the state, and
we've been trying to institute an independent foster carry view program,
which would be one way to be able to do
an inventory of what the child is the child getting
the benefits they need, Is the child alive? Do we
know where the child li is? And over and over
and over again, are you know progressive variety of governors
(19:49):
over the past twenty years that I've lived here have
pushed back on that. So it's one of those issues.
And you know, I hate to general but I think
that we don't really care enough about the condition of
foster children in this country because there are a lot
of issues, but this is one of the most egregious,
(20:11):
one of the most obvious, and quite frankly, one that
we can fix.
Speaker 4 (20:18):
Yeah, definitely, And like you said, there's legislation in Congress
that I think takes a measured approach, and thankfully states
have been starting to stop this practice. I've even talk
to people in other states who know this is happening
and they're trying to stop it. Of course, because if
you know about it, of course you wanted to stop.
But it's just almost a matter of fact that this
stuff is going on. Aside from basically telling states, no,
(20:40):
you can't feel their Social Security money, are there other
fixes in this realm that you think are going to
be helpful?
Speaker 5 (20:46):
Well? I think you know. This is something you and
I have been talking about and writing about a little bit,
you know, just the general carelessness around the kids identifying information.
I mean, so, imagine how angry you would be if
you were a say, twenty year old who aged out
of the foster care system anywhere in the country, only
(21:09):
to discover that a while you were in the system,
someone stole your identity and ruined whatever credit you might have,
so you can't buy that first car, you can't get
that first apartment, and then on top of it, you
find out that your state had collected one hundred and
fifty thousand or two hundred thousand dollars in benefits on
your behalf, but you had never been to the dentist,
(21:33):
you had chronic mental health issues, you were you know,
educationally deprived. I mean, that's what happens. That's what happens
all the time. And I mean even just the regular
subsidy payments that the state gets to support kids in
the system is actually not really being directed carefully enough.
(21:54):
I mean, I use the analogy of a hospital all
the time. You know, if you're if you're a foster
care and you end up in an emergency room in
a hospital with some serious illness, you don't move from
the emergency room to the operating room until you know
your case has been vetted, the information about you has
been conveyed. You're covered by hippo. But in the child
(22:18):
welfare system, which is kind of like an emergency room
full of gunshot victims on a Saturday night, there's none
of that real care. The system uses the privacy shield
that is supposed to be protecting the kids to really
conceal their own activities and so, in other words, the
(22:39):
privacy shield has served not to protect the privacy of
the children, but to cover up the basically the malfeasance
or poor performance of the state agencies themselves. So there's
really a quality control issue here that is baffling to me.
I mean, I've worked all over the country. I've been
(23:00):
to every orphanage in Romania. They had and I say
this with a completely straight face, they had better records
about the children in their care and Romanian orphanages twenty
years ago than we have in the child welfare system sometimes.
And you know, obviously they had a lot of other
factors they were dealing with, and it was you know,
(23:22):
harsh and terrible, but they had systems, and so you know,
there's really no excuse for not creating a more child
specific approach to their privacy, their effectiveness we have. You know,
this just came up, funnily enough in another conversation before
(23:44):
I got on the call. Someone was asking me about
the impact of the Dobs decision, and I said, you know,
there have been a lot of unintended consequences of the
Dobs decision, one of which is that more kids will
enter the foster care system. If women decide that they
can't pair in the child, then there are only really
(24:07):
two options, a private adoption or the child ends up
being committed to the system involuntarily because mom tries to
parent but just can't do it. And so while states
are trying to lower the cost of child welfare in
part by what is actually an admirable national movement to
(24:28):
move children to either keep families together in the first place,
whatever that involves, or to move them into kinship care,
which is a family based approach, or adoption if that's
the last resort. But the sort of careless bookkeeping is
a troubling and problematic part of that system. And of
(24:50):
course when families adopt from the system, to your earlier point,
they're often not aware of these benefits. Some of them
just change the kid's Social Security number as a way
to protect their forward looking identity. So it's just not
it's not a practice that's been well known, but I
think it speaks to the larger issue of why aren't
(25:13):
we doing a better job with this in general? You know,
we talk we're talking a lot about privacy right now,
and certainly you and I share a concern about age
verification and various aspects of the tech conversation. But right
under our noses in all fifty states, in DC, we
have systems of children in the care of the government
(25:34):
who are being exploited and neglected and so of course,
you know, I always say the irony is, well, the
States are suing the tech companies, accusing them of all
kinds of nefarious activity. They're all being sued too, for
a variety of reasons related to their poor performance. So
I just it's there's really there's really no excuse for it.
Speaker 4 (25:55):
And like we've talked about the irs IS and telling
parents when they know that their kids' identities are stolen
and used for tax fraud, and the IRSIG report literally
just says, well, kids don't have tax accounts, so we're
not kind of bother telling them, we're trying to track
them down at all. And the Social Security Administration doesn't
check socials before issuing them to babies, so they're literally
issuing histories of fraud and abuse to babies. There was
(26:17):
a really great story in the Desert, I think like
a week or two ago about it, and it was
helpful to have an illustrative example of like, this is
what's happening, and this is.
Speaker 3 (26:26):
What we're seeing here. So that's exactly it.
Speaker 4 (26:29):
I think we're both frustrated that sometimes the focus is
on tech rather than what the government's actually really in
control of here.
Speaker 3 (26:37):
So from the.
Speaker 4 (26:38):
States that have stepped up here on these laws, New Hampshire, DC, Arizona, Colorado.
Speaker 3 (26:47):
I know you've worked in a lot of places.
Speaker 4 (26:48):
I'm sure not everywhere, But are those states that you
have familiarity with do they tend to do better with
foster youth and child protection in general or are you
not as familiar?
Speaker 5 (27:00):
Well, I for years have tracked pretty closely all fifty states,
and if you look at California, for instance, which made
an effort to fix this practice. But I seem to
recall that I believe my least favorite governor, Governor Newsom,
actually vetoed the bill that would have fixed this problem
in California, which.
Speaker 3 (27:20):
Yeah, I think so true.
Speaker 4 (27:22):
And I'm like, I know he's vetoing some stuff that
I don't like, which is great, but vetoing this Well,
what makes.
Speaker 5 (27:28):
It so important is that twenty percent of all kids
in foster care are in California. California is sort of
like the uber state. It's the largest population of kids
in care. Generally, you can look at any sector, any
issue related to children and look to California for a
substantial sample. And then of course.
Speaker 4 (27:46):
It's is there a reason for that for California being
so not just a.
Speaker 5 (27:51):
Big state, you know, it just has a big population,
and it's it's and it's You can look at almost
any issue, children's, mental health, education or whatever and look
to California as an example. What also, though further confuses
the issues in California is that it is a county
based system. Most states have a state based child welfare system,
(28:11):
but a few, like California, Ohio, a few others have
county based systems. So you know, California is like you know,
a million different child welfare systems. But I think to
your question, what has driven reform in those states is
not necessarily that they have good child welfare systems. It's
that they have principled state legislators who have recognized that
(28:34):
this practice is wrong and have outside of the framework
of the child welfare system, taken it on and pushed
the ball across the goal line. And so I think,
and that's really what has given me hope. And it's
interesting because you and I talk all the time about
state versus federal approaches to things, and you know, it's
(28:56):
the tech stuff. You know, I generally wish the states
would stay down in general and figure out how we
can do a responsible federal policy. But in this case,
it's been kind of interesting to watch the states push
back on this in a principled way. And you know,
Governor Newsom, who is certainly I always describe him as
(29:20):
my least favorite Democrat. But Governor Newsom has done a
lot of virtue signaling about kids in California, various bills
that he's pushed forward. But when it comes to the
practice of protecting children, whether it's releasing pedophiles early from prison,
you know, some of whom served two days in jail,
or vetoing this bill, which is a substantial issue for
(29:45):
kids in California, not so impressive, right. So I think
that what's happening here that's sort of interesting is that
it's kind of democracy and action where we see these
state reps who figure out what's going on, and they
(30:06):
build a movement and they get it done. And I'm
quite certain that the child welfare agencies in those states
are like, no, no, but it happens anyway. And really,
you know, child welfare is a niche issue in the
sense that the average state legislator or staffer, and this
(30:27):
is even true in Congress, doesn't necessarily have that much
subject matter expertise about it, and then whenever there's a
discussion of reform, the governors come forward and generally say,
you know, we already have so much to do in
this regard, you know, don't make us do something else
or don't take our money away. And even if the
(30:47):
money is really as in this case, ill gotten gains.
So it's it's been. It's an interesting issue to work in,
but it's a frustrating issue because at the end of
the day, there hasn't been really any quality control. And
so when you look at including the states that have
taken this social security issue on, almost every state has
(31:11):
been sued for the performance of their child welfare system.
I was in DC for years. I'm from DC, and
I served on the court appointed panel of the receiver
that oversaw the DC child welfare system for a long time.
That was litigated for years and years, and you know
what I saw was that most people's eyes glaze over.
(31:33):
They just think, oh my god, this looks so hard
and there's nothing I can do about it, and I
can't put any more pressure on the system because these
people are already working hard. And that's true in a way,
but the question then becomes, you can't just write off
twenty percent of all the kids and say, well, gee,
they're missing, we don't know where they are. They probably
(31:54):
just ran away. I mean typically if a child is
missing from the system they're over twelve years old, they
automatically classify them as a runaway. So it's an issue
of quality control. And I think that this whole social
Security thing has been probably the most I think certainly
(32:14):
the most troubling example of how we need to do
a better job.
Speaker 4 (32:21):
Yeah, this is this is one of those issues where
I am read into it and I just can't believe
it exists. And I get there sometimes with government, but
usually not to the degree it is here, especially with
I think what you really drove home for me was
the example of like using the multiple social Security numbers,
so creating fraud for kids who have run away, So
kids they're not even caring for and have you know,
(32:43):
lost the ability to care for, maybe their own fault
for it, and.
Speaker 3 (32:48):
That they just want to milk them for money.
Speaker 4 (32:50):
I think we're going to leave it there, but this
was really helpful, and I think we're going to teach
a lot of people about this. It was so interesting
because in the Federalist Society Working Group I'm in the
State and Local work Group. When I brought this up,
no one could believe it. They were just like, hold
on a sec this is a real thing. So I'm
so glad Marien that you're able to join us and
take the time to nerd with us today, And thank
(33:12):
you all for joining.
Speaker 2 (33:13):
Thank you well, Thank you both for sharing your time
and expertise with us today, Marine and Shoshana, And to
our listeners, thank you for tuning in.
Speaker 1 (33:28):
On behalf of the Federal Society's Regulatory Transparency Project. Thanks
for tuning in to the Fourth Branch podcast to catch
every new episode when it's released. You can subscribe on
Apple Podcasts, Google Play, and Speaker For lays from our TP,
please visit our website at Regproject dot org. That's our
egproject dot org.
Speaker 5 (33:56):
This has been a FEDSC audio production.
Welcome to the Regulatory Transparency Projects Fourth Branch podcast series.
All expressions of opinion are those of the speaker.
Speaker 2 (00:18):
Welcome to the Regulatory Transparency Project's Fourth Branch podcast. I'm
Sarah Bankson, Deputy Director of RTP. Today we're happy to
host two experts as they discuss the issue of state
child welfare agencies using the social security benefits of foster
care children. Maureen Flatley is a subject matter expert in
child welfare and child exploitation, with a particular expertise in
(00:41):
government reform and oversight. We're also joined by Shoshana Weissman,
director of Digital Media and Technology and Innovation Fellow at
Our Street Institute. Thank you both for being with us today.
Our listeners can read more about our speakers at regproject
dot org. With that, I'll hand it over to you
Shashana too.
Speaker 3 (01:01):
Thank you so much.
Speaker 4 (01:02):
I'm so excited to talk about this today. So to
start from my work in technology policy and looking into
the identity theft issues. A lot of age verification proposals,
you know when you have to upload government ID, your
social security number, stuff like that to different platforms. There's
real implications for child identity theft, which is a really
(01:24):
really big problem. But when I was diving in here,
I found something that I couldn't believe, that a lot
of state governments steal money from orphans. So I'm going
to read a piece, a short paragraph from Imprint News
that did a really, really great piece on this, and
then we'll dive in and figure out how the heck
this happened. So Imprint News reported that nationwide, an estimated
(01:46):
five percent of all children in youth and foster care
qualify for Social Security Administration, Disability and survivor benefits, but
when they receive them, child welfare agencies often intercept those
payments that can amount to more than nine hundred dollars
a month. An investigation by the Marshall Project and the
National Public Radio estimated that in twenty eighteen alone, child
(02:07):
welfare agencies in forty nine states and the District of
Columbia seized at least one hundred and sixty five million
dollars owed to foster youth and use the money to
pay for the cost of their placements in the child
welfare system. Thankfully, since this report, Arizona, Colorado, New Hampshire,
and Washington, DC passed some comprehensive reforms to stop these practices,
(02:31):
and a lot of other states stepped in for different
levels of reforms. But I think, to start, Maureen, what
the heck is happening here? Why are states stealing money
from literal orphans?
Speaker 5 (02:43):
Well, I think the simple answer is because they can.
And I think it's fair to say that this is
a practice that obviously started a long time ago, and
it was just something that came about over a over
a period of time as states struggled to underwrite the
cost of child welfare programs. And I think it may
(03:07):
have it was probably a function of what we call
revenue maximization, where when a child enters care, states basically
do an inventory of benefits that that child may be
eligible for. So if the child has severe special needs,
or educational deficits, or other kinds of extraordinary requirements, they
(03:31):
look for ways to pay for those additional services. I
first discovered this many many years ago when it was
clear to me that a particular county in California was
actually issuing multiple Social Security numbers to the same kids
so that they could make multiple title for eclaims to
the Feds. But the social Security piece of it surface later.
(03:57):
And the thing that I really want to emphasize is
that the states are capturing this money without the permission
of the children's parents, who are sort of, in many instances,
sort of the predicate beneficiary. They are often not even
using the money for the kid's care. It goes into
(04:19):
a general fund. One of the most pernicious aspects of
this is that in many states there's a significant number
of children in the system that the states can't even locate,
and yet they're collecting money for those kids. So it's
(04:39):
a practice that's going on for a long time. There
have been a number of efforts to stop it in
Congress because you know, obviously, although child welfare is viewed
as a state law issue, there's a huge amount of
federal money that flows into the state systems. And the
states actually opposed the suspension of this practice, and incredibly
(05:00):
Congress went along with it. So it's a long standing
practice and one that was sort of ginned up to other,
you know, to bolster the funding that they already received
from the Feds in the states.
Speaker 4 (05:16):
So I love that you brought up so many things
I really want to dive into. I think I don't
even know where to start. I think we'll start with maybe,
so the state agencies were doing child identity theft on
behalf of themselves to steal money from kids, Like that's
something that you start present.
Speaker 5 (05:33):
In any other context, several aspects of this would probably
be considered criminal behavior. So in other words, they're applying
for federal benefits. I'll give you an example. A family
lost custody of their child. Mom and dad were both
in the grips of the mental health crisis. They were
(05:55):
both receiving SSDI in the state that had custody of
the child realized it, and without their permission or anyone's permission,
they tapped into eligibility for the child. So the child
started the child started receiving significant benefits. Of course, as
far as we know, he never saw any of that money.
(06:17):
In any other context, I'm fairly certain that would be
considered theft. Then you have the right you're stealing money from.
Then you have the issue of the fact that these
children do not have trustees. And so if this were
say senior citizens, and most states have elder care laws
(06:37):
that are even more aggressive than their child welfare laws,
these kids should have each have a trustee who is
their representative paye who can maintain control over the funds
and keep the fund sequestered for that child. For instance,
let's say a child has significant unmet medical needs or
psychiatric needs as a result of whatever disability the parent had.
(07:03):
The money should be put in a trust so that
when that child needs extraordinary services, the trust can then
offset the cost of those services. What happens now is
that there's no trust of any kind. The child often
receives zero services. As I said before, sometimes the state
(07:23):
doesn't even know where the child is, and the state
is using that money to build baseball fields and buy
police guards. So they are really kind of two problems here.
At the front end, you have what you and I
have certainly looked at together as straight up identity theft.
This is not the person who is eligible for the services.
(07:46):
If it's a child, there's no armslength third party guardian
or trustee, And then the money is not being used
for the purpose that it was designed. So really what
we have here is kind of a double edge scam
that the states have continued without really any serious pushback
(08:10):
from Congress. I mean, there have been a couple of
efforts on the part of Congress as you and I
have talked about to suspend this practice, but nothing that
ever amounted too much because the states came forward and said, no, no,
we really need that money. And so what ends up
happening is that you have twenty two thousand kids a
(08:31):
year age out of the foster care system, completely destitute,
most of the medically neglected, educationally neglected, dentally neglected, psychologically neglected.
They can't afford to run an apartment or get a car.
It's really astounding that this has been permitted to continue.
Speaker 3 (08:54):
Oh definitely.
Speaker 4 (08:55):
When I learned about this through you and through the
research here, I was just so astonished that this could
go on. And there's a couple of good government principles
that are being violated here too. Like one is that
and I'm sure sure you've heard of this one too,
that it's just a good idea that when government uses
taxes to pay for something, it should only go to
that one thing, and it shouldn't be in a general fund.
(09:16):
That you want a good means sense to fit where
you can have it because it ties resources to what
they're supposed to go for, and obviously that's not happening here.
And another one is you know, generally I'm worried about
the federal government and being involved in state affairs.
Speaker 3 (09:29):
This is not one of those cases. But in part
because the.
Speaker 4 (09:32):
Social Security funds are supposed to go to the parents,
to the families. That's you know, that's why it's there,
But the money is being totally misused, like this is
not what the money is there for. So I don't
have an issue with the federal government setting and like,
I'm glad states are and that's great, but I'm not
against additional protections to make sure this doesn't happen.
Speaker 3 (09:51):
And another thing too, is.
Speaker 4 (09:52):
Just you know, I'm someone who dons to be pretty
skeptical of government, Like I tend to question a lot,
but I never would have ever imagined that states and
the government would see kids who are in these positions
and abuse their financial resources like this, Like this is
something that's just so far beyond my imagination that even
(10:15):
when I've talked to other people who are very skeptical
of government, they're still like, what the heck, Like how
could this even happen? But I think you bring up
a really good way to round out that not only
is it happening, like to some degree, it's happening a lot,
and it's happening in ridiculous ways, like you know, applying
for multiple Social Security numbers so they can get more
benefits and still you know, send it to the state.
(10:38):
One thing I want to dig in with you a
little bit more on is that I think one thing
that makes it so agreed just is what you started
talking about, where where basically when kids age out of
foster care, they often end up homeless, they have really
poor outcomes. They've just had hard lives and a lot
of difficulties, which makes it all worse. But from you've
done a lot a lot of work over the years
(11:00):
with foster youth, But have you seen how this has
affected them and cases maybe where where they could have
had better outcomes if they had the resources that they
properly were supposed to have.
Speaker 5 (11:15):
I mean, this has been one of the banes of
my professional life for a couple of decades now, because
I see and I was a foster parent in DC
for ten years, and so I would also say that
I've seen this up close and personal in a very
different way. But what is an outrage to me? Well,
(11:38):
first of all, let's go back to what you said
about federal versus state. You know, everybody views child welfare
as a state law issue. However, I would posit that
dating back to the orphan trains in the eighteen fifties,
there has been a fundamentally interstate component to child welfare
that was then really kind of cemented when federal dollar
(12:00):
started blowing to the states a child. The Beast Prevention
of Dreaming Act was created in nineteen seventy four, and
that kind of codified all this stuff from a federal perspective,
and the states had to comply with that to get
the federal part of their share. So stagehild welfare is
funded by a matrix of both federal and state funds
and of course now the Social Security money. So while
(12:25):
I'm not a big government person, and while I certainly
think that it's interesting in this case that the states
have stepped up to mitigate this practice before the Feds
actually have, there is some movement in Congress. I do
think that it might be the moment. You know, there's
always a moment for issues when they finally ripe inadequately
and people start to take them seriously. And I think
(12:47):
we are maybe at that point in Congress, but at
the end of the day, this is a Dickensian scenario
because you know, as you know, I've known probably thousands
of funster youth at this point, and what they would
all say is that, you know, there was nothing good
about being in foster care. They didn't get the things
(13:07):
they needed. I can't think of a single foster youth
I've seen age out that didn't have some dire financial
circumstances that was a victim of identity theft. You and
I talk about this all the time, that the incidence
of identity theft of kids in foster care is dramatically
higher than the general population because so many people handle
(13:30):
their identifying information, And looking at this social security scam
is like the hyper example of that. You know, here
these folks have access to their social Security numbers, but
there isn't even the patina of effort to create a
third party paid to create a guardianship, to create any
(13:50):
kind of trust situation. I've consulted over the years with
some of the world's leading experts on trust in estate law,
and they all consider this to be an illegal taking
of these benefits for the kids. So at the end
of the day, first of all, many of the kids
don't even know this is going on. They have no
(14:13):
idea that the state is collecting, you know, nine hundred
to twelve hundred dollars a month in their names and
they're you know, not going to the dentist, they don't
have glasses, they're in desperate need of educational support. None
of that is happening, okay, even in sort of the
best case scenario. So ultimately, when you look at the
(14:38):
way that these kids are treated, it's not much different
from the chatnel that was the orphan trains, where kids
were basically just dropped off in the middle of nowhere.
The other thing is that in addition to the twenty
two thousand kids who age out every year, and that
number has remained consistent since the nineteen late nineteen nineties
(15:01):
when we did the Adoption and Save Families Act, which
was a massive overhaul of child welfare policy passed in
a very bipartisan way actually, But then you also have
roughly one in nine adoptions from foster care fail those
kids re enter the system. Then you have another component
(15:23):
of kids who are adopted internationally who are also going
into foster care. So the system has become this kind
of basket of failure. I mean, I don't think it's
ever really been very successful, and I would, you know,
I would admit and argue that the States have a
tough job. But at the same time, if they were
(15:45):
running a hospital system and this percentage of patients were
dying or they were misappropriating, say, patients insurance money, I
can assure you that no one would tolerated. And so
the fact that we've allowed this, which was designed to
care for literally the most vulnerable population of children in
(16:08):
this country, to operate so carelessly and so exploitably, well,
you know, it's like I always tay to Jhanna, this
isn't necessarily Congress's fault. This is our fault, because we've
all kind of let this happen and it really needs
to stop.
Speaker 3 (16:28):
Oh definitely.
Speaker 4 (16:28):
I was actually talking with a friend in the South
who was telling me that he had adopted a few
kids and some of them have severe disabilities, and he
was a little bit surprised that he wasn't getting some
benefits along with it, just to help with their care.
And I told him he should go look into this
because I wonder if even when they get adopted, that
this is still happening and I wouldn't be surprised if
(16:49):
that's still the case, and so astonishing that we've But
you're right with astonishing we've let this happen and that
states haven't fixed this issue. But I'd also like to
get into I know, one thing you talk about that
always stuns me too. So much of this is so
new to me, and I know that you're used to it,
and I know that you know it's surprising, but it's
(17:11):
stunning to me that not only are we losing foster
kids at an alarming rate in the system, that they
just disappear and we might never find them again or
know what happened to them, but that even when that's happening,
the government is still trying to find ways to milk
them for money. How you know, isn't I mean there
has to be a level of realizing something is horribly
(17:33):
wrong in that case. But does government just see it
as like, oh, well, we need the money. Is that
all it comes down to you?
Speaker 5 (17:38):
Pretty much? Yeah? I mean, you know, I use the
example of there was a little girl in Florida called
Willia Wilson who was in foster care in the system.
She was adopted at a relatively young age by a
single mom, and the benefits were flowing adoption, subsidy payments,
whatever benefits she was eligible for. And after a period
(18:01):
of time, the neighbors realized that no one was seeing
the child. She wasn't in school, she wasn't playing in
the yard, and so an investigation was triggered and people
realized that she had basically been missing for five years,
but the parent was continuing to collect subsidy payments. This
(18:21):
triggered This triggered an audit in Florida looking to see
what other kids they did couldn't find, and this happened
about fifteen years ago. I can't remember the exact number,
but let's say it was about twenty percent of kids
in the system that the state couldn't even locate for
a variety of reasons. Some of the kids were dead,
(18:44):
some of the kids had left the system, some of
the kids were runaways, and really his case, the belief
was that she had been murdered. I don't believe that
a body was ever discovered. But you know, we see
this all the time. You see this all the time
in fatality cases where kids are literally deceased and yet
the benefits still flow. So now the states have taken
(19:07):
the attitude. And I don't mean to necessarily bash the
states in general, because I think it's sort of a
child welfare agency problem, not a whole state problem. But
they're just leave us alone. This is a hard job,
you know. I live in Massachusetts now and we've had
(19:27):
an alarming number of child fatalities in the state, and
we've been trying to institute an independent foster carry view program,
which would be one way to be able to do
an inventory of what the child is the child getting
the benefits they need, Is the child alive? Do we
know where the child li is? And over and over
and over again, are you know progressive variety of governors
(19:49):
over the past twenty years that I've lived here have
pushed back on that. So it's one of those issues.
And you know, I hate to general but I think
that we don't really care enough about the condition of
foster children in this country because there are a lot
of issues, but this is one of the most egregious,
(20:11):
one of the most obvious, and quite frankly, one that
we can fix.
Speaker 4 (20:18):
Yeah, definitely, And like you said, there's legislation in Congress
that I think takes a measured approach, and thankfully states
have been starting to stop this practice. I've even talk
to people in other states who know this is happening
and they're trying to stop it. Of course, because if
you know about it, of course you wanted to stop.
But it's just almost a matter of fact that this
stuff is going on. Aside from basically telling states, no,
(20:40):
you can't feel their Social Security money, are there other
fixes in this realm that you think are going to
be helpful?
Speaker 5 (20:46):
Well? I think you know. This is something you and
I have been talking about and writing about a little bit,
you know, just the general carelessness around the kids identifying information.
I mean, so, imagine how angry you would be if
you were a say, twenty year old who aged out
of the foster care system anywhere in the country, only
(21:09):
to discover that a while you were in the system,
someone stole your identity and ruined whatever credit you might have,
so you can't buy that first car, you can't get
that first apartment, and then on top of it, you
find out that your state had collected one hundred and
fifty thousand or two hundred thousand dollars in benefits on
your behalf, but you had never been to the dentist,
(21:33):
you had chronic mental health issues, you were you know,
educationally deprived. I mean, that's what happens. That's what happens
all the time. And I mean even just the regular
subsidy payments that the state gets to support kids in
the system is actually not really being directed carefully enough.
(21:54):
I mean, I use the analogy of a hospital all
the time. You know, if you're if you're a foster
care and you end up in an emergency room in
a hospital with some serious illness, you don't move from
the emergency room to the operating room until you know
your case has been vetted, the information about you has
been conveyed. You're covered by hippo. But in the child
(22:18):
welfare system, which is kind of like an emergency room
full of gunshot victims on a Saturday night, there's none
of that real care. The system uses the privacy shield
that is supposed to be protecting the kids to really
conceal their own activities and so, in other words, the
(22:39):
privacy shield has served not to protect the privacy of
the children, but to cover up the basically the malfeasance
or poor performance of the state agencies themselves. So there's
really a quality control issue here that is baffling to me.
I mean, I've worked all over the country. I've been
(23:00):
to every orphanage in Romania. They had and I say
this with a completely straight face, they had better records
about the children in their care and Romanian orphanages twenty
years ago than we have in the child welfare system sometimes.
And you know, obviously they had a lot of other
factors they were dealing with, and it was you know,
(23:22):
harsh and terrible, but they had systems, and so you know,
there's really no excuse for not creating a more child
specific approach to their privacy, their effectiveness we have. You know,
this just came up, funnily enough in another conversation before
(23:44):
I got on the call. Someone was asking me about
the impact of the Dobs decision, and I said, you know,
there have been a lot of unintended consequences of the
Dobs decision, one of which is that more kids will
enter the foster care system. If women decide that they
can't pair in the child, then there are only really
(24:07):
two options, a private adoption or the child ends up
being committed to the system involuntarily because mom tries to
parent but just can't do it. And so while states
are trying to lower the cost of child welfare in
part by what is actually an admirable national movement to
(24:28):
move children to either keep families together in the first place,
whatever that involves, or to move them into kinship care,
which is a family based approach, or adoption if that's
the last resort. But the sort of careless bookkeeping is
a troubling and problematic part of that system. And of
(24:50):
course when families adopt from the system, to your earlier point,
they're often not aware of these benefits. Some of them
just change the kid's Social Security number as a way
to protect their forward looking identity. So it's just not
it's not a practice that's been well known, but I
think it speaks to the larger issue of why aren't
(25:13):
we doing a better job with this in general? You know,
we talk we're talking a lot about privacy right now,
and certainly you and I share a concern about age
verification and various aspects of the tech conversation. But right
under our noses in all fifty states, in DC, we
have systems of children in the care of the government
(25:34):
who are being exploited and neglected and so of course,
you know, I always say the irony is, well, the
States are suing the tech companies, accusing them of all
kinds of nefarious activity. They're all being sued too, for
a variety of reasons related to their poor performance. So
I just it's there's really there's really no excuse for it.
Speaker 4 (25:55):
And like we've talked about the irs IS and telling
parents when they know that their kids' identities are stolen
and used for tax fraud, and the IRSIG report literally
just says, well, kids don't have tax accounts, so we're
not kind of bother telling them, we're trying to track
them down at all. And the Social Security Administration doesn't
check socials before issuing them to babies, so they're literally
issuing histories of fraud and abuse to babies. There was
(26:17):
a really great story in the Desert, I think like
a week or two ago about it, and it was
helpful to have an illustrative example of like, this is
what's happening, and this is.
Speaker 3 (26:26):
What we're seeing here. So that's exactly it.
Speaker 4 (26:29):
I think we're both frustrated that sometimes the focus is
on tech rather than what the government's actually really in
control of here.
Speaker 3 (26:37):
So from the.
Speaker 4 (26:38):
States that have stepped up here on these laws, New Hampshire, DC, Arizona, Colorado.
Speaker 3 (26:47):
I know you've worked in a lot of places.
Speaker 4 (26:48):
I'm sure not everywhere, But are those states that you
have familiarity with do they tend to do better with
foster youth and child protection in general or are you
not as familiar?
Speaker 5 (27:00):
Well, I for years have tracked pretty closely all fifty states,
and if you look at California, for instance, which made
an effort to fix this practice. But I seem to
recall that I believe my least favorite governor, Governor Newsom,
actually vetoed the bill that would have fixed this problem
in California, which.
Speaker 3 (27:20):
Yeah, I think so true.
Speaker 4 (27:22):
And I'm like, I know he's vetoing some stuff that
I don't like, which is great, but vetoing this Well,
what makes.
Speaker 5 (27:28):
It so important is that twenty percent of all kids
in foster care are in California. California is sort of
like the uber state. It's the largest population of kids
in care. Generally, you can look at any sector, any
issue related to children and look to California for a
substantial sample. And then of course.
Speaker 4 (27:46):
It's is there a reason for that for California being
so not just a.
Speaker 5 (27:51):
Big state, you know, it just has a big population,
and it's it's and it's You can look at almost
any issue, children's, mental health, education or whatever and look
to California as an example. What also, though further confuses
the issues in California is that it is a county
based system. Most states have a state based child welfare system,
(28:11):
but a few, like California, Ohio, a few others have
county based systems. So you know, California is like you know,
a million different child welfare systems. But I think to
your question, what has driven reform in those states is
not necessarily that they have good child welfare systems. It's
that they have principled state legislators who have recognized that
(28:34):
this practice is wrong and have outside of the framework
of the child welfare system, taken it on and pushed
the ball across the goal line. And so I think,
and that's really what has given me hope. And it's
interesting because you and I talk all the time about
state versus federal approaches to things, and you know, it's
(28:56):
the tech stuff. You know, I generally wish the states
would stay down in general and figure out how we
can do a responsible federal policy. But in this case,
it's been kind of interesting to watch the states push
back on this in a principled way. And you know,
Governor Newsom, who is certainly I always describe him as
(29:20):
my least favorite Democrat. But Governor Newsom has done a
lot of virtue signaling about kids in California, various bills
that he's pushed forward. But when it comes to the
practice of protecting children, whether it's releasing pedophiles early from prison,
you know, some of whom served two days in jail,
or vetoing this bill, which is a substantial issue for
(29:45):
kids in California, not so impressive, right. So I think
that what's happening here that's sort of interesting is that
it's kind of democracy and action where we see these
state reps who figure out what's going on, and they
(30:06):
build a movement and they get it done. And I'm
quite certain that the child welfare agencies in those states
are like, no, no, but it happens anyway. And really,
you know, child welfare is a niche issue in the
sense that the average state legislator or staffer, and this
(30:27):
is even true in Congress, doesn't necessarily have that much
subject matter expertise about it, and then whenever there's a
discussion of reform, the governors come forward and generally say,
you know, we already have so much to do in
this regard, you know, don't make us do something else
or don't take our money away. And even if the
(30:47):
money is really as in this case, ill gotten gains.
So it's it's been. It's an interesting issue to work in,
but it's a frustrating issue because at the end of
the day, there hasn't been really any quality control. And
so when you look at including the states that have
taken this social security issue on, almost every state has
(31:11):
been sued for the performance of their child welfare system.
I was in DC for years. I'm from DC, and
I served on the court appointed panel of the receiver
that oversaw the DC child welfare system for a long time.
That was litigated for years and years, and you know
what I saw was that most people's eyes glaze over.
(31:33):
They just think, oh my god, this looks so hard
and there's nothing I can do about it, and I
can't put any more pressure on the system because these
people are already working hard. And that's true in a way,
but the question then becomes, you can't just write off
twenty percent of all the kids and say, well, gee,
they're missing, we don't know where they are. They probably
(31:54):
just ran away. I mean typically if a child is
missing from the system they're over twelve years old, they
automatically classify them as a runaway. So it's an issue
of quality control. And I think that this whole social
Security thing has been probably the most I think certainly
(32:14):
the most troubling example of how we need to do
a better job.
Speaker 4 (32:21):
Yeah, this is this is one of those issues where
I am read into it and I just can't believe
it exists. And I get there sometimes with government, but
usually not to the degree it is here, especially with
I think what you really drove home for me was
the example of like using the multiple social Security numbers,
so creating fraud for kids who have run away, So
kids they're not even caring for and have you know,
(32:43):
lost the ability to care for, maybe their own fault
for it, and.
Speaker 3 (32:48):
That they just want to milk them for money.
Speaker 4 (32:50):
I think we're going to leave it there, but this
was really helpful, and I think we're going to teach
a lot of people about this. It was so interesting
because in the Federalist Society Working Group I'm in the
State and Local work Group. When I brought this up,
no one could believe it. They were just like, hold
on a sec this is a real thing. So I'm
so glad Marien that you're able to join us and
take the time to nerd with us today, And thank
(33:12):
you all for joining.
Speaker 2 (33:13):
Thank you well, Thank you both for sharing your time
and expertise with us today, Marine and Shoshana, And to
our listeners, thank you for tuning in.
Speaker 1 (33:28):
On behalf of the Federal Society's Regulatory Transparency Project. Thanks
for tuning in to the Fourth Branch podcast to catch
every new episode when it's released. You can subscribe on
Apple Podcasts, Google Play, and Speaker For lays from our TP,
please visit our website at Regproject dot org. That's our
egproject dot org.
Speaker 5 (33:56):
This has been a FEDSC audio production.
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