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.
Yes. However, these services will not be eligible for IV-E reimbursement. Current prevention services through CSA, PSSF and other local funding will remain in place.
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 victims of sex trafficking
Family-based residential treatment facility for substance abuse
Group homes will be reimbursed if they meet one of the six placement categories. Payment for placements in other types of group homes is restricted by this legislation. After this time, IV-E funding is restricted. During this transition, 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 implementation.
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), facilitates outreach to the family, has registered or licensed nursing staff and clinical staff, and providers after care support for at least 6 months. Within 30 days of placement in a QRTP, children are assessed to determine the appropriateness of the placement (aligning with Virginia’s currently DMAS Clinical Assessment). Within 60 days the Court must approve the child’s placement in a QRTP
Virginia has identified that the “qualified individual” will align with the current DMAS Clinical Assessment and it must be a licensed mental health professional. Licensed Mental Health Professional means 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 in 12VAC35-105-20.
A shortage of foster family homes is not an acceptable reason for placement in a residential setting.
Family First provides opportunities to improve recruitment, approval and retention of foster families. 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.
The Secretary has not given us an official approval to move off the October 1st date. Our more realistic implementation date is likely July 1, 2020 which is also in alignment with DMAS and DBHDS Behavioral Health Redesign as well as the new state fiscal year. Unexpected information, decisions, or delays in Federal guidance or State alignment may cause this date to be adjusted earlier or later.
VDSS will define prevention holistically to include primary, secondary, and tertiary prevention. Family First funding focuses principally upon tertiary prevention (entry into foster care); however, prevention should be seen as a progression of service and program delivery on a continuum.
Virginia is defining “imminent risk” as a child and family’s circumstances demand that a defined case plan is put into place within 30 days that identifies interventions, services and /or supports and absent these interventions, services and/or supports, foster care placement is the planned arrangement for the child.
Candidate for foster care" is defined as a child identified in a prevention plan as being at imminent risk of entering foster care but who can remain safely in the child's home or in a kinship placement as long as services or programs that are necessary to prevent the entry of the child into foster care are provided. The term includes a child whose adoption or guardianship arrangement is at risk of a disruption or dissolution that would result in a foster care placement."
VDSS elected to use the Three Branch structure developed through two successful National Governor’s Association awards. This model has proven to be efficacious as an organizing structure for system change. Representatives include judges, legislators, and leadership from all child-serving state agencies. In addition, child and family advocates, professional organizations such as the Virginia League of Social Service Executives (VLSSE), and interest groups such as the Virginia Coalition of Private Provider Associations (VCOPPA) and the Virginia Association of Counties (VACO), have participated in ongoing meetings since June 2018.
VDSS is also working closely with each of the local advisory committees (Prevention, CPS and Foster Care) to inform and shape potential guidance and practice changes.
Because of the scope of Family First and impact across the entire system, we will involve all interested stakeholder groups in implementation to the extent possible.
Leadership from the Department of Behavioral Health and Disability Services (DBHDS) and the Virginia Association of Community Services Boards (VACSB) are key members in the Three Branch structure.
VDSS recognizes that system change cannot happen in isolation. We value the role that the CSBs play across the Commonwealth and particularly in certain geographic areas. The new requirements of Family First may enhance the role of the CSBs and other partners.
DBHDS is working with CSB’s to provide training opportunities for programs that may be reimbursed through Title IV-E funds to ensure that CSB’s can continue to play a critical role in service delivery.
The more we can share information and communicate with our partners, the better. Providers are an integral part of implementation and we want them involved from the outset. In your community, encourage providers to become informed about the provisions of Family First. Share information posted on the Family First webpage, information located on the intrant and hold information meetings to discuss key provisions of the legislation as it relates to your community. Also encourage them to stay connected to their provider associations like VCOPPA. Service providers may also reach out to us with any questions they may have by emailing us at familyfirst@dss.virginia.gov .
It is critical that Family First become integrated within our current child welfare services continuum. KinGAP and all service programs be connected with and integrated into Family First implementation. KinGAP provides another permanency option for youth after discharge from foster care where return home and adoption are not an option. IV-E maintenance payments are allowable when the youth was living in a kinship foster home situation for at least six consecutive months, all other permanency goals are ruled out, and the family is willing to commit to the child permanently.
With Family First all kinship families (whether an informal or formal arrangement) are entitled to prevention services when the child is determined to be a candidate for foster care.
Judges approve or disapprove QRTP placements and there is a distinct difference between the judicial roles of approving versus ordering a child into a particular placement. Family First prevention services are voluntary; however, a Court may simultaneously be involved with a family while the family is receiving prevention services.
The Children’s Bureau has created a federal clearinghouse with evidence-based programs that can be reimbursed with federal dollars. Services and programs must be “promising”, “supported”, or “well-supported” based on an evidence structure similar to the well-known California Evidence-Based Clearinghouse for Child Welfare. Upon implementation of the Family First Prevention Services Act, Virginia will be utilizing the federal clearinghouse for Evidence Based Programs. See the specific services that have been approved below.
The first release from the Clearinghouse was released at the end of June. The current rankings for each of the 12 initial services are as follows:
Well-Supported:
Parent Child Interaction Therapy Functional Family Therapy
Multisystemic Therapy Parents as Teachers
Nurse-Family Partnerships
Supported:
Families Facing the Future
Promising:
Trauma-Focused Cognitive Behavioral Therapy
Does Not Meet Criteria:
Children’s Home Society of New Jersey Kinship Navigator Model
Kinship Interdisciplinary Navigation Technologically Advanced Model
Multisystemic Therapy for Child Abuse and Neglect
Not Yet Rated:
Healthy Families of America
Motivational Interviewing
Methadone Maintenance Therapy
We can draw down funds for any service that are in the well-supported, supported and promising categories (50% of our draw down must by in the well-supported category). We are still waiting on the clearinghouse to rank Healthy Families, Motivational Interviewing and Methadone Maintenance Therapy. You may sign up for Clearinghouse updates on their website, so be sure to do that if you want to receive updates expediently. We have not heard any information about when the rankings for the “not yet rated” programs will be released, or when the next list for review will be released other than “late summer.”
The first step is to become knowledgeable about Family First by reading summaries and attending meetings where Family First is on the agenda. Visit the Family First webpage often to see what new information is posted.
Consider starting a local Three Branch team where you bring all branches of the government (judicial, legislative and executive) in your community to talk about the opportunities and challenges associated with Family First for your agency and community. Include community based providers, advocates, and nonprofit organizations who support children and families. Assess the current needs of your community and areas where Family First may assist.
Please reach out to us with any questions you may have by emailing us at familyfirst@dss.virginia.gov
This can be confusing. A child is a reasonable candidate if the child only needs a service that is not a mental health treatment, substance abuse treatment or in-home parent skills training.
A child is a candidate for foster care if the child and /or caregiver need mental health, substance abuse treatment or in-home parent skills training.
Are you required to be certified in one of the many trauma informed models, or only required to demonstrate trauma informed practices as defined in the clearinghouse.
Family first does not stipulate that a program needs to be certified in a specific trauma informed model. We are discussing this information and will provide clarity around this question.
The Secretary has not given us an official approval to move off the October 1st date. Our more realistic implementation date is likely July 1, 2020 which is also in alignment with DMAS and DBHDS Behavioral Health Redesign as well as the new state fiscal year. Unexpected information, decisions, or delays in Federal guidance or State alignment may cause this date to be adjusted earlier or later.
Youth who are in placement upon implementation of Family First are “grandfathered” into their placement and funding sources. Only new youth who enter care are subject to Family First requirements. Youth who move from placement to placement after implementation will be affected by Family First funding.
There are no changes to the IV-E applicability rules for children and youth in foster care.
Is there a process for getting services in the Federal Clearinghouse?
The Handbook is 60 pages which describe how evidence based services for prevention services will be evaluated. The Handbook describes a research based process for evaluating programs. In June 2018, the Federal Government requested feedback for programs to be considered in the Clearinghouse. The Federal Clearinghouse will be hosted on a website and it’s our understanding there is a method for the public to interact with the Clearinghouse and provide recommendations. When you think about making recommendations, leverage executive level expertise (e.g. VDSS) as those are likely to be considered first.
The Administration for Children and Families has released the Title IV-E Prevention Services Clearinghouse will provide the official list of all programs. Programs that are rated as well supported, supported, or promising are eligible for IV-E reimbursement. Virginia will follow the Title IV-E Prevention Services Clearinghouse.