MODULE 6: Family First Prevention Services Act and Qualified Residential Treatment Programs
Key Concepts & Definitions:
In February of 2018 new federal child welfare legislation was enacted. This legislation, called the Family First Prevention Services Act (Family First), replaced the category of “group and institutional placement” with four specialized non-family placement settings:
- Qualified Residential Treatment Programs
- prenatal, postpartum, or parenting supports for youth-supervised settings for youth 18+ who are living independently
- settings providing high-quality residential care and supportive
- services to children who have been or are at risk of being sex-trafficking victims
The intent of Family First is to prevent the separation of children from their families and to ensure that children whose needs cannot be safely met in a family setting receive high-quality residential treatment interventions that allow them to successfully transition back to family care. Family First limits federal reimbursement of restrictive settings to needed therapeutic interventions for only as long as is needed to meet the best interests of the child.
A Qualified Residential Treatment Program (QRTP) is a newly defined level of care in a licensed child care institution created under the Family First act. The QRTP is considered the most restrictive acceptable level of care and is intended to provide therapeutic interventions for only as long as is needed to meet the best interest of the youth.
The following are additional requirements of the QRTP
- There is a twenty-five-bed limitation for publicly run QRTPs.
- The QRTP can be used for children (up to age 18 who are in out-of-home care) for whom an assessment determines that the child’s needs cannot be met in a less restrictive, family-based setting because of their serious emotional or behavioral disorders or disturbances.
- The QRTP has a trauma-informed treatment model designed to address the needs, including the clinical needs as appropriate, of children with serious emotional or behavioral disorders or disturbances, and can implement the necessary treatment identified in the child’s assessment.
- The QRTP has registered or licensed nursing or other clinical staff who provide care within the scope of their practice as defined by state law and who are available 24/7. (Staff do not have to be directly employed and are not specifically required during business hours but must be on-site consistent with the QRTP trauma-informed treatment model.)
- The program facilitates family outreach, documents how this outreach is made and maintains contact information for any known biological family and fictive kin of the child.
- The QRTP facilitates family participation in the child’s treatment program if family participation is in the child’s best interest.
- The program provides discharge planning and family-based aftercare supports for at least six months post-discharge.
- The QRTP is licensed and accredited by the Commission on Accreditation of Rehabilitation Facilities (CARF), the Joint Commission on Accreditation of Healthcare Organizations (JCAHO), the Council on Accreditation (COA), or another Health and Human Services approved accrediting entity.
- The program documents how the child’s family is integrated into the child’s treatment, including post-discharge, and how sibling connections are maintained.
Family First does not define what aftercare is but does indicate that it is part of the QRTP and is required for at least six months. In this BBI Family Engagement Toolkit, the following definition for Aftercare is used:
Aftercare refers to providing services and supports to youth and families in their homes and communities after the in-residential program services and supports have been completed. Traditionally, many residential programs have not provided comprehensive aftercare services. With these programs, the term post-residential discharge referred to after the youth was discharged from the in-program residential services. For residential programs with intentional and comprehensive aftercare services and supports, the term post-residential discharge refers to after aftercare services and supports end. Aftercare services include in-home work and support for the youth and family, working directly with different community service and support organizations, implementing effective safety plans (including backup safety plans) for all family members, and ensuring that natural supports and networks are in place for all family members.
Some residential programs have formal partnerships with community providers to provide all or some of the needed aftercare services and supports. Other residential programs provide all in-home aftercare services and support with their own staff in addition to developing informal partnerships with community providers to supplement what is offered.
Family First defines three other acceptable settings. In addition to QRTPs, these are the non-family settings that Title IV-E funds can reimburse: 1) prenatal, postpartum, or parenting supports for youth; 2) supervised settings for youth 18+ who are living independently, and 3) settings providing high-quality residential care and supportive services to children who have been or are at risk of being sex-trafficking victims.
Family First also allows for Title IV-E funds to reimburse room and board for a child who is placed in out-of-home care with their parent in a Family-Based Residential Substance Abuse Treatment Program (FRSAT) while the parent receives the needed substance use treatment.
Module 6 Family First & QRTP Resources
Building Bridges Initiative Family First Prevention Services Act Informational Document: Comparison of Federal Requirements for Qualified Residential Treatment Programs (QRTP) and Psychiatric Residential Treatment Facilities (PRTF) (2019, March). Building Bridges Initiative.
Building Bridges Initiative Technical Assistance Offerings to Support Oversight Agencies and Residential Programs with Ensuring Quality Implementation of Family First Prevention Services Act Opportunities for Residential Intervention. (2019, Fall). Building Bridges Initiative.
Kuppinger, A., Hust, J.A., Hunt, P., Mosby, P., Hammack, S., & Caldwell, B. (2020). Putting families first: Strategies to transform and advance family engagement and partnership. In B. Caldwell, R. Lieberman, J. LeBel, & G.M. Blau (Eds.), Transforming Residential Interventions: Practical Strategies and Future Directions (pp. 8–30). Routledge.
ADDITIONAL RESOURCES:
The National Standards for Culturally and Linguistically Appropriate Services in Health and Health Care (National CLAS Standards)