The Family First Prevention Services Act (FFPSA) is the most sweeping federal legislation to impact child welfare funding in over 30 years. The Act, which passed in February 2018, allows states to use existing child welfare federal funds in new ways. It also contains several provisions aimed at improving outcomes for children and families receiving child welfare services. This article focuses on two primary provisions.
1. Funding for Prevention Services
The FFPSA allows states to use federal child welfare funding (often referred to as IV-E funds) for families and their children to receive services that prevent removal from the home and entry into foster care. Services include assessment and treatment for mental health and substance use disorders, as well as parenting services. This is different from the current model, which uses IV-E funding to cover services and placement for children after they have entered foster care. This is a significant step toward building statewide capacity to help families receiving child welfare services safely parent their children in their own homes. States may opt in to Prevention Services as early as October 2019.
2. Limitations on Congregate Care Funding
FFPSA places new limitations on how IV-E funding can be used for foster children in congregate care placements such as group homes and other non-family settings. FFPSA restricts use of IV-E funds to the first two weeks of group care placements, unless the child has needs that meets one of these exceptions:
- Clinical need for placement in an eligible Qualified Residential Treatment Program.
- A group setting that provides prenatal, post-partum, or parenting supports (e.g., a maternity home).
- A setting that provides high quality, supportive services to children and youth who have been found to be, or are at risk of becoming, sex trafficking victims.
- The child is age 18 or older and living independently in a supervised setting.
- The setting is a licensed, residential, family-based treatment facility for substance abuse (includes facilities where children are placed with a parent receiving treatment).
If a child is in a group placement that does not meet one of these criteria, the child may remain in that placement, but IV-E cannot be used for that placement after 14 days. These limitations on group care funding are in response to the wealth of research that indicates children who live with families have better outcomes than those who spend long periods in congregate care without medical/clinical necessity.
Impact in North Carolina
If a state opts in to the Prevention Services between October 2019 and October 2021, the state must also adopt the group care funding limitations. Even if a state chooses not to opt-in to the Prevention Services, the group care funding limitations become mandatory in October 2021. This gives states time to develop plans to address congregate care funding for placements that may be impacted.
North Carolina is determining how these changes will impact children and families. We anticipate changes to congregate care funding will require increased efforts to identify relatives and kin and recruit and retain licensed foster families.
Summary
The NC Department of Health and Human Services (DHHS) is developing strategies to integrate the opportunities presented in FFPSA with Rylan’s Law to enhance the quality of child welfare services and availability of resources statewide.
To learn more about FFPSA, you may access the recording and PowerPoint presentation from our June 2018 FFPSA Stakeholder’s Kickoff Meeting at https://www.ncdhhs.gov/family-first-prevention-services-act-information. DHHS will share more information about FFPSA in the months to come.
