1. Family First Prevention Services Act (FFPSA)
Colorado CASA Conference
October 20, 2018

2. Overview What the heck is FFPSA? What does FFPSA actually do?
Placement Prevention Services
Ensuring Appropriate Placements
How is Colorado responding to FFPSA?
How are CASAs affected by FFPSA?

3. What is FFPSA and where did it come from?
FFPSA Background (Title IV-E and the IV-E Waiver)
FFPSA Enacted
Framing FFPSA

4. What is FFPSA and where did it come from?
FFPSA Background (Title IV-E and the IV-E Waiver)
FFPSA Enacted
FFPSA Context

5. What is FFPSA and where did it come from?
FFPSA Background (Title IV-E and the IV-E Waiver)
IV-E = children in the child welfare system
IV- E Wiaver = piloting prevention programs

6. What is FFPSA and where did it come from?
FFPSA Background (Title IV-E and the IV-E Waiver)
FFPSA Enacted
FFPSA Context

7. What is FFPSA and where did it come from?
FFPSA Background (Title IV-E and the IV-E Waiver)
FFPSA Enacted
Framing FFPSA

8. The “why” behind FFPSA
Preserving families – “family” first; children do best in a family-like setting
Getting incentives right – open up Title IV-E for placement prevention services
Paying for what works/evaluate programs to make sure they're effective
Children in foster care have the right to be placed in the “least restrictive” setting relative to their needs
Systemically addressing substance use/opioid issues
When a child cannot be safely placed in a family-like setting, there should be appropriate treatment options available

9. Overview What the heck is FFPSA? What does FFPSA actually do?
Placement Prevention Services
Ensuring Appropriate Placements
How is Colorado responding to FFPSA?
How are CASAs affected by FFPSA?

10. Placement Prevention Services
FFPSA
Placement Prevention Services

11. Opportunities in Child Welfare
CO FFPSA Project April 2018
Opportunities in Child Welfare
Pre-2018 (no FFPSA) FFPSA
Federal funds for foster care Federal funds for prevention
Services for the child only Prevention for parents, kin and child
Income test to qualify NO income test, just what at-risk family needs
No dedicated kinship navigator 50% reimbursement for kinship navigators
No funds for child placed with 12-months of federal funds for such placement
parent in residential treatment

12. New Requirements and Funding for Prevention
Requires prevention services and programs to be promising, supported, or well-supported, to qualify for reimbursement
Requires the federal government to issue guidance to states on criteria required for services or programs under this section in October This guidance must include a pre-approved list of services and programs that satisfy the requirements
In June, the Children’s Bureau released a Federal Register Notice for Comments on initial criteria and programs for review in a Clearinghouse of evidence-based practices.
New Requirements and Funding for Prevention

13. New Requirements and Funding for Prevention
What: Allows the following evidence-base services to be reimbursed
Mental health prevention and treatment services provided by a qualified clinician for not more than a 12 month period
Substance abuse prevention and treatment services provided by a qualified clinician for not more than a 12 month period
There is no limit on how many times a child and family can receive prevention services

14. New Requirements and Funding for Prevention
What: Allows the following evidence-base services to be reimbursed
Would allow states to receive 50 percent federal matching funds for expenditures on Kinship Navigator Programs
Would also need to meet requirements of a “promising, supported or well supported practice”
There is no limit on how many times a child and family can receive prevention services

15. Other FFPSA Requirements
Requires states to submit a prevention and services program plan
Requires model licensing standards for relative foster family homes
Requires states to documents steps taken to track and prevent child maltreatment deaths
Provides $8 million in FY 2018 in grants to states and tribes to support recruitment and retention of high quality (kinship) foster families
Requires the plan to include a description of how the state will administer the program, determine eligibility, train caseworkers and numerous other items

16. Optional Prevention Services continued
Services can be provided when the need of the child, parent or caregiver for the services or programs is directly related to either:
The safety, permanence or well-being of the child, or
Preventing the child from entering foster care
12-month clock starts from the date a child is identified in a “prevention plan” (required by the law) as either:
A child who is a candidate for foster care, or
A pregnant or parenting foster youth in need of the services

17. Service Requirements
To be eligible for federal reimbursement, services provided under Title I must:
Be trauma-informed, as defined in the law
Be practices that are evidence based - “promising, supported, or well-supported” as each is defined in the law
Be specifically listed and described in detail in a new prevention programs component of the state plan
Be individually subjected to a “well-designed and rigorous” evaluation as part of the state plan, unless the requirement is waived by the Secretary

18. Residential Treatment Facilities
Allows foster care maintenance payments for children placed with parents in licensed residential substance use disorder treatment facilities for up to 12 months
Recommendation for the placement must be in the child’s case plan prior to the placement being made
Treatment program must also include parenting skills training, parent education and individual and family counseling in a trauma-informed model

19. Kinship Navigator Programs
Would allow states to receive 50 percent federal matching funds for expenditures on Kinship Navigator Programs
Would also need to meet requirements of a “promising, supported or well-supported practice,” as defined
Would be available without regard to IV-E eligibility of the child whose caregiver received the services

20. Family Reunification Services Timeframes
Amends timeline for provision of family reunification services
Allows for indefinite provision of services while a child is in foster care
Allows for up to 15 months of post-reunification services to families after a child returns home

21. Ensuring Appropriate Placements
FFPSA
Ensuring Appropriate Placements

22. Valid Placement Settings for Federal Payment
A licensed, residential family-based facility
A qualified residential treatment program (QRTP)
A setting specializing in providing prenatal, postnatal or parenting supports for youth
A supervised independent living setting for youth >18
A setting providing high-quality residential care and supportive services to children who have been found to be, or are at risk of becoming, sex trafficking victims

23. QRTPs Defined
A QRTP is a licensed, certified and accredited program that:
Has a trauma-informed treatment model
Is able to implement the treatment identified for the child pursuant to the child’s assessment
Has registered or licensed nursing staff and other licensed clinical staff who meet requirements of treatment model
Facilitates participation of family in the child’s treatment, to the extent appropriate and in the child’s best interests
[READ SLIDE]

24. QRTPs Defined continued
A QRTP is a licensed and certified program that:
Facilitates outreach to family members, including siblings, documents how that outreach is made
Documents how family members are integrated into the treatment process for the child, including post-discharge, and how sibling connections are maintained
Provides discharge planning and family based aftercare support for at least 6 months post-discharge

25. Court Oversight of QRTP Placements
Within 60 days of the start of a QRTP placement, a family or juvenile court or other court of competent jurisdiction must:
Consider the assessment, determination and documentation made by the qualified individual;
Determine whether the needs of the child can be met through placement in a foster family home or, if not, whether placement of the child in a QRTP provides the most effective and appropriate level of care for the child in the least restrictive environment and whether the placement is consistent with the short- and long-term goals for the child; and
Approve or disapprove the placement

26. Court Oversight of QRTP Placements continued
The agency must submit evidence at each status review and permanency hearing that:
Demonstrates that ongoing assessment of the strengths and needs of the child continues to support the prior determination supporting placement in a QRTP
Documents the specific treatment or service needs that will be met for the child in the placement and the length of time the child is expected to need the treatment or services; and
Documents efforts made by the agency to prepare the child to return home or be placed with a fit and willing relative, a legal guardian, an adoptive parent, or in a foster family home

27. Court Improvement Program Amendments
To receive grants in future, courts must:
Provide training to judges, attorneys and other legal personnel on federal child welfare policies and payment limitations with respect to children in foster care who are placed in settings that are not a foster family home
Requires state plans to certify that in response to these new payment limitations, the state will not enact or advance policies or practices that would result in a significant increase in the population of youth in the state’s juvenile justice system

28. Foster Family Recruitment & Retention/Support
$8 million for competitive grants to support recruitment and retention of high-quality foster families
States with the highest percentage of children placed in non-family settings are supposed to be the focal recipients

29. Chafee Independent Living Program
Renames the program to be the “Chafee Program for Successful Transition to Adulthood”
Program is intended to “support all youth who have experienced foster care at age 14 or older in their transition to adulthood through transitional services”
Reworks activities to be more broadly focused on “practicing” daily living activities (as opposed to “training” youth on certain activities)

30. Chafee Independent Living Program
Requires ILP services to be provided to non-minor dependents in states that have extended foster care beyond age 18
Services must be provided to age 23 for youth that have aged out of foster care
Codifies provisions for redistribution of unspent funds to states that apply for these funds
Allows youth to receive education and training vouchers up to age 26, but for no more than 5 years

31. Opportunities in Child Welfare
CO FFPSA Project April 2018
Opportunities in Child Welfare
Pre-2018 (no FFPSA) FFPSA
Federal funds for foster care Federal funds for prevention
Services for the child only Prevention for parents, kin and child
Income test to qualify NO income test, just what at-risk family needs
No dedicated kinship navigator 50% reimbursement for kinship navigators
No funds for child placed with 12-months of federal funds for such placement
parent in residential treatment

32. How is Colorado Responding to FFPSA?
This Photo by Unknown Author is licensed under CC BY-SA

33. How is Colorado Responding to FFPSA?
The FFPSA Advisory Committee
This Photo by Unknown Author is licensed under CC BY-SA

34. How are CASAs Affected by FFPSA?
Apples vs Oranges? FFPSA = prevention; remaining with family; and implementing evidence-based best practices Dependency & Neglect (D&N) = filings based on investigations of abuse & neglect

35. How are CASAs Affected by FFPSA?
CO FFPSA Project April 2018
How are CASAs Affected by FFPSA?
Potential Consequences:
Fewer court filings and fewer children/youth entering out-of-home care
Fewer court filings might reduce the need for CASAs, as your role is currently defined today

36. How are CASAs Affected by FFPSA?
CO FFPSA Project April 2018
How are CASAs Affected by FFPSA?
Opportunities:
There’s a need for CASAs throughout the state – currently, CASAs are not involved in all cases… perhaps CASA programs could work with their local departments to think of ways they might still partner.  Also, CASA may want to look at another population like delinquency or youth who are “Crossover”
SB 154 and Crossover Youth Plans: room for CASAs to support youth deeply involved in the system?  CASAs are not assigned on a delinquency case but some do work on them when a D/N youth picks up delinquency charges.  

37. How are CASAs Affected by FFPSA?
CO FFPSA Project April 2018
How are CASAs Affected by FFPSA?
Opportunities:
CASAs serving more children/youth in their homes as opposed to in out-of-home placement (assuming a D&N is filed).  Should/Could CASA's efforts align?...  CASA's often stay on cases even after children/youth return home, so some CASAs are accustomed to advocating for children/youth who are at home.
CASA involvement in FFPSA committees and subcommittees and the Finance SubPAC

38. CO FFPSA Project April 2018
FOR MORE INFORMATION
Luis Guzman CDHS Office of Children, Youth and Families (303)