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FFPSA changing funding for child welfare services

FFPSA Hands

By CARF International
(Editor's note: This article was originally published August 30, 2018 but has been updated to reflect current information. You may also visit www.carf.org/ffpsa for current official updates.)

For U.S. providers of child-welfare services, one of the most impactful laws to take effect this year has been the federal Family First Prevention Services Act or FFPSA.

In a move intended to help children who are at risk of entering the foster-care system to remain with their family members, the new law broadens the reimbursement model and offers federal funding for up to 12 months of mental health services, substance use treatment, individual and family counseling and/or in-home parenting skill training. FFPSA also changes the requirements for non-foster family home settings that can be funded through Title IV-E child welfare entitlement money and limits funding for most of those organizations to two weeks of services per participant.

The Department of Health and Human Services is to provide more guidance about the law to states by late fall of this year. The expanded guidance is to include criteria for “promising, supported, or well-supported practices” the law requires for prevention services and a list of preapproved services and programs that satisfy the requirement.

A key takeaway for providers of residential services that are not in a foster-family setting—but wish to still receive Title IV-E funding—is that they are required to be nationally accredited. By October 2019, they must meet licensing requirements as Qualified Residential Treatment Programs and be accredited by an approved, nonprofit independent accreditor.

FFPSA can be seen as part of the worldwide trend toward prevention as a way to contain healthcare costs and address consumer demand. One CDC study found more than two-thirds of U.S. adults believe the U.S. healthcare system should emphasize more preventive care, while 84 percent favor public funding for such prevention programs.

The new FFPSA regulations will apply to the following kinds of services seeking Title IV-E funding:

  • Foster family homes, as defined in the law
  • Settings for pregnant or parenting youth in foster care
  • Independent living settings for youth 18 and older
  • Licensed residential facilities for treatment of substance abuse where a parent can have their child with them in the facility
  • Settings providing residential care and support to children and youth at risk for sex trafficking
  • Programs that meet criteria for a new category known as Qualified Residential Treatment Programs. Besides being accredited, such facilities must be based on trauma-informed treatment models; provide 24/7 available registered/licensed nursing and clinical professionals; use outreach programs to try to engage participants’ families; and provide discharge planning and family-based after-care supports for at least six months following discharge.

Organizations now providing such services should verify funding criteria and requirements through their relevant state agencies. For other questions about related accreditation, contact CARF International, the independent nonprofit that has accredited more than 50,000 health and human service programs across the globe.

For more information, here are links to official resources available (Updated October 3, 2018):

The legislation (FFPSA-related pages are 169–206): https://www.congress.gov/115/bills/hr1892/BILLS-115hr1892enr.pdf
HHS guidance issued to states:

  • April 2018 Information Memorandum
    www.acf.hhs.gov/cb/resource/im1802
    Informs States and Tribes of the enactment of the Family First Prevention Services Act and provides basic information on the new law.
  • July 2018 Program Instruction
    www.acf.hhs.gov/cb/resource/pi1807
    Provides instruction for: 1) changes to the title IV-E plan requirements as a result of the Family First Prevention Services Act that are effective as of January 1, 2018 and later; and 2) delayed effective dates for title IV-B/E plan requirements.
  • October 1, 2018 FFPSA implementation status-update letter from HHS
    www.carf.org/FFPSAStatusUpdate
    Lists HHS actions and pending actions related to FFPSA implementation. Provides new projected release date (Late Fall 2018) for additional guidance to States and Tribes on prevention-services qualifying criteria. Provides clarification to States and Tribes on deadlines regarding requests for delay in implementation.

8/30/2018
(Child and Youth Services)


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