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The Family First Prevention Services Act
What Residential Providers Need to Know
Lisette Burton, J.D.Vice President, National Advocacy & Public Policy
July 23, 2018
Agenda• Background on the Family First Prevention
Services Act (FFPSA)• Overview of the Law• Answer to frequently asked questions• Opportunities and action• What’s happening in the field?• Wrap Up
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Background
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What is the FFPSA?
• While passage of this impactful legislation took some by surprise, advocates began work to pass this law several years ago.
• The Family First Prevention Services Act was passed into law on February 9, 2018 as part of the Bipartisan Budget Act of 2018.
• The law expands the use of federal Title IV-E child welfare entitlement dollars to prevent entry into foster care, and it restricts funds for out-of-home care that is not a foster family home.
Background
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What is the FFPSA?
• While passage of this impactful legislation took some by surprise, advocates began work to pass this law several years ago.
• The Family First Prevention Services Act was passed into law on February 9, 2018 as part of the Bipartisan Budget Act of 2018.
• The law expands the use of federal Title IV-E child welfare entitlement dollars to prevent entry into foster care, and it restricts funds for out-of-home care that is not a foster family home.
Bipartisan Budget Act of 2018Multiple Provisions Focused on Children &
Families:
– CHIP Reauthorization – extended for total of 10 years– Maternal, Infant and Early Childhood Home Visiting
(MIECHV) Reauthorization for five years– Community Health Clinics reauthorized– Supporting Social Impact Partnerships to Pay for
Results– Family First Prevention Services Act
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Background
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What is the FFPSA?
• While passage of this impactful legislation took some by surprise, advocates began work to pass this law several years ago.
• The Family First Prevention Services Act was passed into law on February 9, 2018 as part of the Bipartisan Budget Act of 2018.
• The law expands the use of federal Title IV-E child welfare entitlement dollars to prevent entry into foster care, and it restricts funds for out-of-home care that is not a foster family home.
Family First Prevention Services ActParts 1-3
Prevention Activities Under IV-E (optional)• Funds child room and board when placed with a
parent in a family residential substance abuse treatment facility
• Funds promising, supported, and well-supported:– mental health and substance abuse prevention and
treatment provided by a qualified clinician– In-home parent skill-based programs– How Long?
• for up to 12 months – Who is eligible?
• “Candidates for foster care” and pregnant or parenting foster youth.
• Promotes kinship navigator programs8
Family First Prevention Services ActPart 4
Ensuring the Necessity of a Placement that is not a Foster
Family Home (mandatory)• After two weeks, only certain out-of-home
care placements are eligible for federal reimbursement (per placement, not per foster care episode!)
• 4 “Specified Setting” categories1. Programs for pregnant/parenting youth2. Independent living programs for youth 18+3. Programs serving youth who have been or are at
risk of sex trafficking4. New classification of residential intervention
called a Qualified Residential Treatment Program
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Family First Prevention Services ActPart 4 continued
Qualified Residential Treatment Program (QRTP) • Must be licensed and accredited• “Qualified Individuals” (not employed by the
state or affiliated with any provider) will need to conduct assessments and approve placement within 30 days
• Judges will need to approve placement within 60 days and at regular status hearings
• Clinical and Nursing staff will need to be onsite according to the treatment model and available 24/7
• Providers must maintain documentation of family engagement, including contact with siblings
• Requires 6 months of post-discharge support and family-based aftercare
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Family First Prevention Services ActPart 4
Ensuring the Necessity of a Placement that is not a Foster
Family Home (mandatory)• After two weeks, only certain out-of-home
care placements are eligible for federal reimbursement (per placement, not per foster care episode!)
• 4 “Specified Setting” categories1. Programs for pregnant/parenting youth2. Independent living programs for youth
18+3. Programs serving youth who have been or
are at risk of sex trafficking4. New classification of residential intervention
called a Qualified Residential Treatment Program11
FAQ: Do I have to become accredited?
FAQ: What does this mean for small group homes?
Become a foster home?• Foster homes defined as:
– Home of an individual or family
– This means that the term may no longer include “group homes, agency-operated boarding homes or other facilities licensed or approved for the purpose of providing foster care…” as previously permitted in the regulatory definition at 45 CFR 1355.20(a) if that facility is not the home of an individual or family.
Become a QRTP?• New staff?• New treatment model?• Are you trauma-
informed?• Can you become
accredited?• Who can you serve best?
FAQ: Is there a size limit for providers of residential care?
• The term ‘child-care institution’ means a private child-care institution,
• or a public childcare institution which accommodates no more than 25 children,
• which is licensed by the State in which it is situated
*Watch out for the IMD Rule…
Impact • Depends on how the regulations are written
– Impact will be different state by state– Prevention funding and out-of-home care limitations effective
October 2019 - states can request up to a two-year delay by November 9th
• New federal entitlement for prevention of entry into foster care– The opioid crisis is impacting child welfare systems nationwide– New state matching dollars are required
• Access to the right care at the right time– Out-of-home care capacity is a challenge
• Potential impact on continuums of care– Mental health– Juvenile Justice
What’s happening in the field?States are at varying points in the planning process
– Examples: Colorado, Nebraska, Iowa, Louisiana, Florida, North Carolina
– Many states are discussing a delay to allow time to plan
State Budget Considerations
Financial Support for Implementation Efforts– If funding were available, what would your priorities
be?
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What’s happening in the field?• Are you participating in an FFPSA workgroup led by your
state child welfare agency?
• Is your state or local provider association taking coordinated action regarding FFPSA?
• Does your individual organization have a coordinated plan to influence and respond to FFPSA implementation?
• Does your organization currently provide, or have interest in providing, mental health, substance use disorder, and/or in-home parent skill-based services that could help prevent entry into foster care?
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Opportunities • Don’t forget about the Florida Quality Standards
for Residential Care
• Beyond the QRTP…how do you fit into your state’s continuum of care?
• Mandated aftercare services should improve long-term outcomes for youth with greater needs
• The field needs our collective expertise
Take action!• Track and inform
rulemaking by HHS
• Take part in implementation at the state and local level
• Continue to educate staff and partners
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Stay informed!
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Human Resources Subcommittee Hearing on The Opioid Crisis:
Implementation of the Family First Prevention Services Act (FFPSA)
Tuesday, July 24, 2018 at 10:00 AM
