Daily Update February 6, 2018


Major Development for Family First Prevention Services Act

From Association of Children's Residential Centers 2/6/2018

 

Major Development for

Family First Prevention Services Act

February 6, 2018

On February 5, 2018 at 10:00 PM, a House Continuing Budget Resolution (CR) was posted to the public. This proposed CR funds the government through March 23rd and includes a full year of defense appropriations and billions in funding for Community Health Centers. There are many partisan provisions, including changes to tax law, changes to Medicare, and proposed elimination of the Prevention Fund as offsets, causing Sen. Chuck Schumer to already declare the House CR "dead on arrival." The House CR also includes the Family First Prevention Services Act (FFPSA), building off the version included in the 21st Century Cures Act in 2016. The bill will be heard by the House Committee on Rules today at 1:00 pm EST.

The Social Impact Partnerships to Pay for Results Act is also included. A 29-page summary of the bill offers a section-by-section overview. The full text of FFPSA, Title VI in the CR, begins on page 357 of the CR. Most notably, the prevention activities are paid for in part by a delay in the adoption assistance phase-in and by the limitations on reimbursement for out-of-home placements that are not foster family homes; but there are new offsets outside of child welfare spending, including changes to child support enforcement fees and limitations of incentive payments to prisons for certain data reporting.

Effective October 1, 2019 (with the option for states to delay for two years, while also delaying access to prevention funding), IV-E reimbursement for out-of-home placements that are not foster family homes would be limited to:

Specified Settings: Qualified Residential Treatment Programs (QRTPs); programs for pregnant and parenting youth; independent living programs for youth 18 and older; and "settings providing high-quality residential care and supportive services to children and youth who have been found to be, or are at risk of becoming, sex trafficking victims."

The major change to this version of FFPSA is with regards to the staffing pattern of the newly created category of residential intervention called a QRTP.  QRTPs must be licensed and accredited, have a trauma-informed treatment model, facilitate and document family involvement and outreach, and provide at least 6 months post-discharge family-based aftercare support.

(NEW) QRTPs have a registered or licensed nurse and other licensed clinical staff on-site "in accordance with the [QRTP's] treatment model" and available 24 hours a day, 7 days a week. (NEW) Nurses and behavioral health staff do not have to solely be employees of the QRTP.

*This is an advocated-for change from previous one-size-fits-all versions of the bill that required nurses to be "on-site" during business hours and left it unclear as to whether programs could contract with third parties to provide nursing and clinical services (a particular concern for rural areas).*

With bipartisan commitment to avoid a second government shutdown, there is a sense of urgency to pass a short term CR by the February 8th deadline. This makes it likely that the CR will quickly pass during a floor vote in the House. The Senate will likely make significant adjustments or craft their own CR, which may look very different from the House version and may or may not include FFPSA. Either way, this will move quickly over the next couple days, and we will keep you informed.

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SAVE THE DATE  2018 Georgia Conference on Children and Families October 17-19, 2018


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