An update on the Family First Prevention Services Act

August 9, 2019

All children and teens should grow up in safe, stable and secure family that supports their long-term well-being. Research shows that growing up in a family is essential for all kids, especially those who have experienced abuse or neglect.

Most children and teens who receive help through child welfare services are not removed from their homes. In fact, in 2018, of the 20,814 Colorado children and their families involved in an open child welfare case:

  • 68 percent received services in their own homes
  • 32 percent of children and teens were placed in an out-of-home placement (kinship care, foster care, group home/center or a residential child care facility)

The Family First Prevention Services Act (Family First) is a federal law that allows local child welfare agencies to use federal funding (Title IV-E or IV-E) to pay for services that prevent the removal of a child or teen from their home. Previously, Title IV-E funding could only be used to pay for the cost of out-of-home placement services.

Family First gives Colorado additional resources to promote innovations and flexibility thanks to the federal funding that can be used for placement prevention services. Family First also puts limitations on federal funding for placements that are not in family-like settings. 

Removing a child or teen from their home can be traumatic for the entire family, so caseworkers avoid that whenever possible. Family First aligns with Colorado’s philosophy that children and teens should grow up with a family. 

If it is not possible to ensure the safety and well-being of a child or teen in their own home, a caseworker looks to family or friends willing to provide a temporary home while the parent or caregiver works to improve the situation at home. These families are known as “kinship families.” Any safe adult with an established and trusted relationship with a child or young person - grandmas, uncles, teachers, neighbors or even a friend’s parent - can be a kinship parent.

Family First provides an exciting opportunity to implement new in-home services, but change can also bring uncertainty. Family First implementation is complex and more reforms will be needed to continue to transform the child welfare system in Colorado, but we know Family First will help us all as we work to ensure children, youth and families thrive.

What to know more? Keep reading about ...

How will Colorado prevent out-of-home placement?

Family First aligns with Colorado’s philosophy that children and teens should grow up with a family. Additionally, the law requires quality prevention services with a proven track record based on data, facts and evidence.

To help ensure children and teens continue to live with their parent(s) as their parent(s) address safety concerns, Family First will allow Colorado to fund up to 12 months of services to prevent a child or teen from entering foster care.

Prevention services can include:

  • In-home parenting skill training
  • Mental health services
  • Substance abuse prevention and treatment

Prevention services must be trauma-informed, evidence-based, approved, and subject to a well-designed and rigorous evaluation.

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Is Colorado closing residential child care facilities, group homes, and group centers? No, but their business models may change.

Children and teens in foster care should grow up in the least restrictive setting. Sometimes, short-term treatment in a residential child care facility can help provide the services and stability a child or teen needs before they transition to a family-like setting, where they are better able to address their past traumatic experiences.

Family First creates a new facility license type called a qualified residential treatment program (QRTP), which many currently licensed and accredited residential child care facilities may become.

To ensure these residential programs are effective and therapeutic, a QRTP must:

  • Be designed to be treatment-focused and temporary. 
  • Provide access to 24-hour nursing.
  • Provide six months of services after a young person has transitioned out of the program.
  • Be accredited by a national accrediting entity.

Family First limits the use of federal funding to four types of congregate care placements:

  1. A qualified residential treatment program
  2. A setting specializing in providing prenatal, postpartum or parenting supports for young people
  3. A supervised independent living setting for young adults age 18-21
  4. A setting that provides high-quality residential care and support services to survivors of child sex trafficking or those at risk of becoming sex trafficking victims

Licensed group homes and group centers can continue to operate and serve children and teens with intellectual and developmental disabilities, children and teens placed through Colorado Medicaid, private placements and young people who are transitioning from a secure Division of Youth Services facility into a community-based placement.

To continue to serve children and teens who have experienced abuse or neglect and who cannot safely live with their parent or caregiver, group homes and group centers may consider changing their business models.

The Colorado Department of Human Services is working with group homes and group centers to provide more information and resources so that:

  • Group homes can become foster homes, certified to care for six young people
  • Group centers, which have rotating staff, may become QRTPs
  • Group homes and/or group centers can provide community-based, evidence-based services designed to prevent an out-of-home placement

Join the Colorado Department of Human Services for a provider meeting on August 29, 2019, at Adams County Human Services to learn more about these changes. Email Susan Franzen at susan.franzen@state.co.us for more information.

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How will services be paid for?​

Family First incentivizes the use of Title IV-E funding to prevent the removal of children and teens from their homes. For prevention services that qualify under Family First, Colorado will continue to share costs 80/20 with counties, with 50 percent of the state’s portion coming from federal funds. 

For out-of-home placements, the daily reimbursement rate will remain the same; however, the state’s ability to use Title IV-E funding for those placements may change. 

Under Family First IV-E eligible placements include:

  • A foster family, including a certified kinship family
  • Group homes, group centers, residential child care facilities approved as:
    • A setting specializing in providing prenatal, postpartum or parenting supports for young people
    • A supervised independent living setting for young adults age 18-21
    • A setting that provides high-quality residential care and support services to survivors of child sex trafficking or those at risk of becoming sex trafficking victims
  • A qualified residential treatment program

A child or youth is IV-E eligible if their family income meets specific guidelines. 

For an out-of-home placement in a Family First eligible setting, the state will continue to share costs 80/20 with counties, with 50 percent of the state’s portion coming from federal funds.

For an out-of-home placement that does not qualify under Family First, the state and county cost-sharing will remain the same - 80/20 -  but the state will contribute the full 80 percent because federal IV-E funding will not be available.

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When and how will the law be implemented?

In order to access Title IV-E funds for placement prevention services available through Family First, each state must submit a federal Prevention Program Plan (Plan) to the Children’s Bureau for review and approval.

While there is no deadline by which a state must submit their Plan, Colorado’s goal is a January 2020 "opt-in." Colorado continues to assess its readiness to implement Family First through a Family First Implementation Team. This team also consists of several workgroups, each focused on key areas, including:

  • Assessment
  • Child & Family Plans
  • Service Array
  • Qualified Residential Treatment Programs

As the federal government continues to review and update its national “Title IV-E Prevention Services Clearinghouse” (Clearinghouse) with approved promising, supported and well-supported services and programs, Colorado continues to review and access its current list and level of evidenced-based services and programs offered throughout Colorado.

As the Service Array workgroup continues to review and discuss current evidenced-based services and programs available in Colorado, it will be important for this workgroup to keep the federal evidence-based criteria in the forefront to ensure the services and programs identified on Colorado’s Plan are eligible for federal reimbursement.

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Will children and teens in group homes or group centers have to move out? No, but they should grow up with a family whenever possible.

Whenever possible, caseworkers look for kinship providers - family members and other trusted adults - to care for a young person while their parent(s) addresses safety concerns. Throughout a child welfare case, caseworkers are required to conduct a diligent search for possible kinship providers to provide a safe, temporary home for children and youth in an out-of-home placement. This requirement does not change.

If no kinship family or foster family is available, children and youth may remain in their same group home or group center. The reimbursement formula will change from 50 percent federal/30 percent state/20 percent county to 80 percent state/20 percent county.

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How can I stay involved or learn more?

  • Attend one of our public meetings. Find meeting dates and locations and past meeting minutes on the Family First Prevention Services Act Implementation Team website.
  • Attend a provider meeting to understand how Family First may impact your business. The next provider meeting will be held on August 29, 2019, at Adams County Human Services. Email Susan Franzen at susan.franzen@state.co.us.
  • Subscribe to our newsletter and our memo series. Complete this form and check the box next to “I want to receive a notification when the Office issues a memo.”

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