Public Policy Updates
Impact of Racism on Child and Adolescent Health
Official policy statement released by the American Academy of Pediatrics. POLICY
QRTP/IMD Clarification and Q & A
The guidance doc clarifies existing CMS policy regarding Institutions for Mental Diseases (IMDs) and its potential for impact on Qualified Residential Treatment Programs (QRTPs). CMS_FAQ
Family First Transition Act
The draft proposal has been agreed upon by both the Senate Finance and House Ways and Means Committees. Expected to pass soon and will be retroactive to October 1. TRANSITION ACT
The Title IV-E Prevention Services Clearinghouse has issued a Transitional Payments guidance document while states await review of programs and services. GUIDANCE DOC
The Prevention Services Handbook of Standards and Procedures Now Available:
The Title IV-E Prevention Services Clearinghouse Handbook issued by the Children's Bureau regarding how they are going to select prevention programs to review for eligibility for IV-E funding is now in distribution. Specifically, it addresses the following: Procedures for identifying programs and services and associated research studies for review or re-review; standards for assessing the design, execution, and findings of research studies and for rating programs and services; and definitions of key terms. HANDBOOK
Finance Committee Addresses Clearinghouse Concerns:
Recently, Senators Chuck Grassley and Ron Wyden, drafted and sent a letter to the Secretary of Health and Human Services, Alex Azar, that expressed concern over the limited scope and slow moving process of the ABT in reviewing programs for approval. This signals a recognition of states' concern over timely reimbursement affecting their ability to support programs that provide quality care. Read Full Letter Here
Title IV-E Prevention Services Clearinghouse Update: OVERVIEW
According to the letter to State Child Welfare Directors in early January of this year, the goal has been, and remains, to review and rate as many services and programs as quickly as possible through the Clearinghouse to support states’ efforts to improve outcomes for children and families through implementation of FFPSA.
The revised initial criteria and selection of the first few services and programs for review was developed with a multitude of recommendations, comments and consultations with key stakeholders in the field. The Clearinghouse will continue to identify and prioritize additional services and programs for review on a rolling basis. They fully expect to add to the body of title IV-E reimbursable services as expeditiously as possible.
The Clearinghouse will provide additional information, a more detailed description of the revised initial criteria, procedures for systematic review and re-review, and definitions of key terminology in the forthcoming Prevention Services Clearinghouse Handbook of Standards and Procedures, which we expect to be issued early April 2019.
For the full timeline, key differences between the statutory requirements of FFPSA and the standards and procedures used by other clearinghouses and other implementation details – click here.
Model Licensing Standards for Foster Care Released: click here
JJDPA Reauthorization Webinar: click here
Public Policy Committee Meeting Summary: FFPSA and Juvenile Justice
Reviewed new information released by the federal government’s Administration for Children and Families (ACF) meant to help better understand and implement the prevention program requirements of the 2018 Family First Prevention Service Act (FFPSA). The Family First Prevention Service Act expands the use of federal Title IV-E child welfare dollars (funds that used to only be available once a child was placed in foster care) for evidence-based services to prevent foster care placement. The FFPSA created a new category of residential intervention, Qualified Residential Treatment Program (QRTP), that includes residential as an eligible specified setting for out-of-home placement of youth in hopes of preventing foster care placement. The ACF outlines the details about the prevention requirements of the FFPSA in a Program Instruction document released late 2018. This program instruction covers categories such as prevention program eligibility criteria, states’ oversight requirements to ensure child safety and monitor quality, and important financial updates.
The Policy Committee was also excited to note the passing of the Juvenile Justice and Delinquency Prevention Act Reauthorization. The JJDPA was first passed in 1974, and although it has been updated since, it had not been reauthorized since 2002. The JJDPA helped to create standards and expectations for youth involved in the local and state-based juvenile justice systems across the country. The Act also focuses on delinquency prevention for youth. The newly reauthorized bill includes updates and improvements that are based on research and seek to address modern-day situations that were not addressed in older versions of the act. For example, delinquency prevention must be evidenced-based, and trauma informed and include proper screening and assessment activities for youth involved. The use of isolation and restraint is strongly discouraged, and a push to eliminate their unreasonable use is a highlight of the act. Also, creation or improvement of programs that are sensitive to the needs of girls at-risk or already involved with the juvenile justice system is encouraged. Such programs will need to provide mental health, substance abuse and other services as needed to address youth who have been trafficked and forced to engage in commercialized sex activities (also known as CSEC- commercial sexual exploitation of children).
The Committee shared enthusiasm for the reauthorization as many of the youth we serve are at-risk or involved in the juvenile justice system. Further, this reauthorization provided a great example of the benefits of policy efforts informed by research activity.
Information & Guidance from HHS
ACF Information Memo - A summary of the law created by ACF - Click here
ACF request for comment on the prevention clearinghouse that people are currently responding to (with the deadline of July 22nd) - click here