HHS Releases First Guidance on Family First Services
Late Friday, the Administration on Children and Families released its first guidance and preliminary list of services for funding under the Family First Prevention Services Act (PL 115-123)—(FFA). The guidance at ACYF-CB-PI-18-09 gives an overview of some of the initial decisions made by HHS in the interpretation and implementation of the Family First Act. Included in the release are a number of forms for state decision making including Attachment C that provides the initial HHS criteria and the first list of services and programs selected for the first review (and presumably) eligibility for funding under the services part of the new law. The initial list of a dozen programs includes:
Prevention Services and Programs
- Parent-Child Interaction Therapy
- Trauma Focused-Cognitive Behavioral Therapy
- Multi-systemic Therapy
- Functional Family Therapy
- Motivational Interviewing
- Multi-systemic Therapy
- Families Facing the Future
- Methadone Maintenance Therapy
In-Home Parent Skill-Based:
- Nurse-Family Partnership
- Healthy Families America
- Parents as Teachers
Kinship Navigator Programs
- Children’s Home Society of New Jersey Kinship Navigator Model
- Children’s Home Inc. Kinship Interdisciplinary Navigation Technologically-Advanced Model (KIN-Tech)
In selecting the initial list, the Children’s Bureau said that additional services and programs will be added for review on a rolling basis. They also said that they would give priority to services and programs recommended by the state and local government administrators. The first programs for review included these state preferences as well as programs that have been rated by the California Evidence-Based Clearinghouse; programs evaluated by Title IV-E Child Welfare Waiver Demonstrations; a recipient of a Family Connection Discretionary Grant; and recommendations solicited from agencies and partners within the Administration for Children and Families, Health Resources and Services Administration, the National Institutes of Health, the Centers for Disease Control and Prevention, the Office of the Assistant Secretary for Planning and Evaluation, and the Substance Abuse and Mental Health Services Administration.
Of note, the new guidance from HHS indicates that states can continue to provide services to an eligible child/family beyond the first 12-month service period on behalf of the same child for additional 12-month periods. In order to claim title IV-E for each additional 12-month period, the state must determine and document in the child’s prevention plan that the otherwise eligible candidate for foster care or pregnant/parenting youth meets the requirements under the law.
Other notable decisions by HHS in response to comments including those by CWLA:
- In-home services are broadly defined and does not mean all services are physically in the home
- There is no further definition in trauma-informed approach beyond recognized principles and approach and trauma specific interventions
- In submitting a five-year plan for prevention services states may file that at any time in the year
- There is separate guidance for Indian tribe Title IV-E plans
- States may submit a separate prevention plan that serves tribal communities if there is a state-tribe agreement
- Prevention services may be provided for youth in care including up to age 21 if a state extends foster care to that optional older age
- A candidate for foster care may include a guardianship or adoption disruption or dissolution
- A child in a kinship placement but not in the care of the Title IV-E agency could be considered a candidate for foster care and thus eligible for services
- States may provide services by different geographic area (no state-wideness requirement) and they can provide different services in different areas
By and large, the guidance is very flexible although limited by the number of services initially examined. The actual law is specific in terms of studies, results and evaluation before a mental health, substance abuse and in-home services can be covered. The guidance is also an in-depth view of the challenges and the potential the new law holds.
For an examination of the state plan requirements people can read a copy ofAttachment B the state plan pre-print. In their announcement, the Children’s Bureau said that the law and guidance:
“provides an opportunity for states to re-think dramatically how they serve children and families and creates an impetus to focus attention on prevention and strengthening families as our primary goals rather than placing children in foster care as our main intervention. The Children’s Bureau strongly encourages all title IV-E agencies to take this opportunity to not only use the title IV-E prevention program to fund these important services, but also to envision and advance a vastly improved way of serving children and families, one that focuses on strengthening their protective and nurturing capacities instead of separating them.”
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