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A QRTP is a non-family based placement which provides treatment to children using a trauma-informed treatment model. QRTP’s must be accredited by a non-profit accrediting agency (JACHO, CARF, COA, Teaching Family Association, and Educational Assessment Guidelines Leading Towards Excellence (EAGLE)), facilitate outreach to the family, have registered or licensed nursing staff and clinical staff, and provide after care support for at least 6 months. Within 30 days of placement in a QRTP, children must complete a clinical assessment to determine the appropriateness of the placement (aligning with Virginia’s current DMAS Clinical Assessment). Within 60 days the court must approve the child’s placement in a QRTP.

VDSS is currently working towards an implementation date of July 1, 2020. Unexpected information, decisions, or delays in Federal guidance or State alignment may cause this date to be adjusted.

Yes. The AFDC standards to determine IV-E eligibility when entering foster care have not changed. Children will be assessed for IV-E eligibility through the normal process. IV-E eligible children do not lose their eligibility; however the placement may not be IV-E reimbursable. Children already in a congregate care placement when Family First is implemented will be “grandfathered” as far as IV-E is considered. Only new placements will be subject to the Family First guidelines.

Family First will not do away with group homes. However, when Family First is implemented, IV-E maintenance payments will be limited to the following six placement categories:

  • Family foster homes (including relatives) with six or fewer children in the home
  • Placements for pregnant or parenting youth
  • Supervised independent living for youth 18+
  • Qualified Residential Treatment Programs (QRTP) for youth with treatment needs
  • Specialized placements for youth at risk of or victims of sex trafficking
  • Family-based residential treatment facilities for substance use disorders

Group homes will be reimbursed if they meet one of the six placement categories. Payments for any other placements are restricted by this legislation. During a transition period, CSA funds may be utilized to cover the cost of IV-E ineligible placements; however, this is expected to be a short-term support through the implementation period.

Youth who are in placement upon implementation of Family First are “grandfathered” into their placement and funding sources. Only new youth who enter care or youth who move to a new placement after implementation are subject to Family First requirements.

A shortage of foster family homes is not an acceptable reason for placement in a non-family based placement. The intent of the legislation is to reduce the use of group homes and non-family based care whenever possible.

There is a statewide campaign to raise awareness and recruit additional foster parents. It is important that LDSS also work towards recruiting more foster families and ensuring that relatives are assessed for placement in every case.

Non-family based placements should be the exception, not the rule. During JLARC’s review they found that youth were being placed in non-family based placements because there was nowhere else for them to go, not because of clinical need. VDSS is working on a Diligent Recruitment Plan that will be maximizing family based placements so youth do not have to leave their community. VDSS is partnering with the Virginia Fosters Initiative (VA Kids Belong and the Governor’s Office) to connect foster families, faith based communities, and community partners to support parents and youth involved in the foster care system.

Local agencies and providers should ensure that concurrent planning begins at the beginning of placement in foster care, for every placement, and is occurring throughout the life of the case. Concurrent planning is following “Plan A”, while creating and following “Plan B” simultaneously.

VDSS also received $851,000 to begin building and expanding evidence based services in communities to provide services for children and their families. VDSS is providing training opportunities for providers to become certified in Multisystemic Therapy, Functional Family Therapy and Parent-Child Interaction Therapy. VDSS will continue to provide resources, as funding is available, to support the development and expansion of evidence based programs in Virginia.

VDSS will continue to work in collaboration with OCS, DMAS, DBHDS and community based providers to ensure the best level of care is available for the youth.

The funding source should not drive the services available and provided to youth. Programs should begin preparing to become a QRTP designated program now. If a program chooses not to take a certain funding source, the program may not be able to receive full payment from another funding source if there are other available funding sources which they did not chose to utilize by becoming a QRTP.

Virginia has identified that the “qualified individual” will align with the current DMAS Clinical Assessment requirements and it must be a licensed mental health professional. Licensed Mental Health Professional (LMHP) meaning a physician, licensed clinical psychologist, licensed professional counselor, licensed clinical social worker, licensed substance abuse treatment practitioner, licensed marriage and family therapist, certified psychiatric clinical nurse specialist, or licensed behavior analyst as defined: DMAS refers to DBHDS’ definition and DBHDS refers to DHPs definitions. DHP has the authority of who meets the criteria of a LMHP. It is the court’s responsibility to make sure a “qualified individual” completed the assessment.

Family First specifies five accrediting bodies: the Joint Commission on Accreditation of Healthcare Organizations (JACHO), the Commission on Accreditation of Rehabilitation Facilities (CARF), the Council on Accreditation (COA), The Teaching Family Association, and Educational Assessment Guidelines Leading toward Excellence (EAGLE).

Accreditation does not convey automatic status as a QRTP in Virginia. Virginia will define QRTP designation through collaboration with VDSS Division of Family Services, VDSS Division of Licensing and DBHDS Division of Licensing. VDSS Family Services will designate QRTP’s in Virginia through an application process, which is expected to be available in November 2019.

The federal QRTP requirements are slightly different than Virginia’s current licensing requirements. VDSS Licensing and DBHDS Licensing sections are exploring aligning the QRTP requirements to their regulations. In preparation for implementation of Family First, VDSS Division of Family Services will designate programs as a QRTP through an application process. The designation will not affect a program’s license status.

The QRTP designation will apply to all of the locations/sites covered by a single license. There are license specific and location specific requirements for QRTP. Therefore, each licensed program location must have its own QRTP designation independent of another licensed location.

Six months of aftercare support is required. It is the program’s responsibility to seek to provide this support to the best of its ability and to document any challenges in providing those services and why.

Family First believes that reunification is important and should be valued as long as it is safe to do so. Steps should be taken to show effort to get safe involvement of the siblings. The safety and well-being of the child is of utmost importance.

Yes; but the QRTP program is responsible for making sure that aftercare support happens. Virginia does not allow a program to assign liability/responsibility to a subcontractor. The contract staff would still be subject to the safety requirements.

Services for children who are discharged from a QRTP may be funded through the local CSA program or through Medicaid (for Medicaid covered services) as is the current situation. A program may also explore adding the cost of aftercare support to the cost of the actual residential treatment.


Family First requires that the QRTP provides aftercare support. A determination has not been made that every youth who is placed in a non-family based placement requires CSB case management.

Family First states that a program may contract for nursing staff. The QRTP is not required to have a direct staff-employer relationship with nursing staff. Given the intent of the legislation, it is not anticipated that utilizing Urgent Care or Emergency Rooms would satisfy the requirement of the law. It should be noted that all contracted staff will need to have an “employee file” onsite with all the required trainings and background checks conducted by the provider and be maintained by the provider.

No. The 12-month review requirement includes an expectation that plans for discharge should not wait until the 11th month, services should be time limited, and that placements will be found and exceptions will be more rare than common. There will be emphasis on moving the process along.

The intent is that a child will always have a safe place to go. The Three Branch and inter-agency teams will work to offer clarity around this issue.

Family First does not speak to that directly. A definitive decision has not been made, but it will likely be a partnership through the program and the local agency.

In any foster care court hearing, youth should be present.

There is nothing in the law that states that programs must send a staff person to a court hearing. It may be helpful for program staff to talk with the local agency worker, the child’s Guardian ad Litem, and CASA worker to determine appropriate representation at court hearings. If the court is reviewing a placement decision, it would likely be beneficial for a staff person to be available to testify to the provision of services, the child’s needs, and why the child needs to continue to receive services in order for the court to make an informed decision. Written reports are generally not admissible in court. Arrangements for transporting the child to the hearing should also be determined collaboratively.

The Court Improvement Program (CIP) of the Supreme Court of Virginia trained judges in 2018 and will do so again in 2020. CIP has also trained approximately 600 local attorneys and guardian ad litems (GALs).

A judge makes their decision based on information presented and the relevant statutes. The reports and information given to the court should provide what is needed for the judge to make a fully informed decision. If a different placement is deemed necessary by the court, there is a grace period for a change in placement most fitting to the child’s needs.

Foster care hearings are conducted in the locality in which the child’s family resides (the funding locality) and where the LDSS holds custody.

These will need to be addressed on an individual basis. The FAPT, Judge/Commissioner should be collaborating to provide the best plan for the child. However, statute provides the judge with final authority for determining a child’s placement and local CSA programs must comply with the court’s orders.

Discharge planning is a part of the treatment in the QRTP. An ongoing plan for the next steps for the child should be under review by everyone working with the child throughout the life of the placement.

Decisions or recommendations have not been made at this time regarding funding levels. The General Assembly required DMAS to conduct a rate analysis which resulted in DMAS asking the residential facilities to submit the cost reports. Results of DMAS's rate study will determine whether there will be an adjustment to rates.

VDSS and DMAS leadership are determining how to proceed.

The expectation is that all children placed in a non-family based placement will receive the same high level of treatment. It is not the intention to have different levels of care Family First legislation only impacts funding for Title IV-E eligible youth who are in foster care.

Non-family based residential programs who care for children in foster care who are eligible for IV-E funding. Any type of program licensed by DSS, DBHDS or DJJ; regardless of whether it is or is not a Medicaid provider; can apply to be a QRTP.

There are no fees to apply to be or to remain a QRTP.

VDSS Division of Family Services will accept applications on a rolling basis. Programs may apply when they are ready. However, programs are encouraged to apply prior to July 1, 2020, in order to ensure continuous funding streams.

No. Follow-up must include speaking with the child and family members monthly, as well as engagement with the Family and Permanency Team.

Yes, a discharge plan is required, regardless of discharge reason.

No. However, programs in this position are encouraged to contact the Family First team. It might be appropriate for the program to start the application process while waiting for accreditation approval.

Application Related FAQ

This will be determined on a case-by-case bases. Please contact the Family First team before submitting an application if this applies to your program.

No. Resumes must be submitted for all the clinical and nursing staff associated, affiliated or employed with the program who are needed for QRTP requirements, regardless of the number of staff.