Want to take a bit of a deeper dive into the Family First Prevention Services Act?  

In 2018 the Family First Prevention Services Act (FFPSA) ushered in a new era for child welfare in the United States. We are not even being dramatic, it’s a game changer. One aspect of the Act is the focus on getting children out of congregate care. This is big stuff. So here we go…

Congregate care, represents a wide array of out-of-home settings, including group homes, child care institutions, residential treatment facilities, emergency shelters, and in-patient hospitals. These settings are facing significant changes come October 1st of this year and, to be honest, many are not ready. They have to become Qualified residential treatment programs (QRTPs) in order to get most reimbursement for their services from the government.

Although directors and teams at these homes and facilities are often well intentioned, overall we believe these changes are going to throw much of the service provision for children in these facilities into disarray. So we’re doing a tiny part by sharing what we know with you.

This excerpt, taken from the Capacity Building Center for States is one of the clearest and most succinct write ups we’ve seen:

The FFPSA promotes the use of congregate care as a limited strategy that is to be used primarily to support the complex clinical needs of children and youth with significant exposure to trauma.

The FFPSA created the QRTP designation to meet the needs of children and youth who require residential treatment to address serious emotional and behavioral disorders (Children’s Bureau, 2018b). The law mandates the following requirements (Children’s Bureau, 2018b):

• The FFPSA restricts title IV-E reimbursement for any child or youth in a congregate care setting that extends beyond 14 days, unless the program is licensed and accredited as a QRTP and a functional assessment indicates the setting is in the best interests of the child
• The assessment must indicate that the QRTP is the least restrictive treatment intervention possible and that the child’s clinical needs will be met by the facility’s treatment model
• The assessment process must include a family and permanency team, which may include parents, other relatives, fictive kin, professionals such as therapists or teachers, and additional supports selected by youth over age 14

The state must transition the child to an alternate program if the assessment determines a child’s needs can be more appropriately met in a less restrictive setting u States are required to develop procedures to prevent inappropriate mental health diagnoses that may lead to an unnecessarily restrictive setting. The legislation does not restrict length of stay. However, within 60 days of a child’s admission to a QRTP, the court must review the admission. In addition, the FFPSA requires increased review when a child younger than 13 years of age is in residential care for 6 months and increased review when a child over 13 years of age is in residential care for 12 consecutive months. For these children, the state also must submit to the Children’s Bureau justifying documentation with the signed approval of the IV-E agency head (Children’s Bureau, 2018b). QRTPs are intended to be time limited and meet the needs of youth who need temporary, intensive clinical care before they are discharged into a family setting (Children’s Bureau, 2018b).

Feel overwhelming to read? Imagine what it’ll feel like to implement. We believe deeply in the right of children and families to stay together but also want the transition of our system to be done intentionally and confidently. We are in for a bumpy road folks.

Further, a QRTP is required to do family search & engagement work. We LOVE this but again, are worried about how quickly a team that has traditionally not done family finding, can begin to do this work in earnest.

Here’s another blurb from the trusty Capacity Building Center for States:

The FFPSA requires family engagement before, during, and after stays in a QRTP (Children’s Bureau, 2018).

• To ensure that the adults closest to the youth are directly involved in decision-making, a Family and Permanency Team must be developed as part of the assessment process. The team can include parents, other relatives, fictive kin, professionals such as therapists or teachers, and additional supports selected by youth over age 14. The child’s case plan must include contact information for each member of the team and must document accessibility of meetings and justification for any assessment decision that does not reflect the team’s recommendation.
• Family involvement in treatment, including the maintenance of sibling connections, must be documented. QRTPs must conduct and keep documentation of outreach to family, as well as updated contact information for family and fictive kin.
• Families must actively participate in discharge planning, and 6 months of family-based aftercare must be provided following discharge.