Note: This column has been updated
When the Family First Prevention Services Act breezed through the House Ways and Means Committee and on to passage from the full body, Youth Services Insider noted that many of the bill’s supporters had stayed on board. Among the supporters, we wrote, is the so-called “triad”: the Alliance for Strong Families and Communities, the American Public Human Services Association (APHSA) and the National Organization of State Associations for Children (NOSAC).
Turns out, at the time, we were only two-thirds correct. The Alliance and APHSA have remained supportive of Family First as the bill’s prevention services options have narrowed and its constraint on group care has been honed.
NOSAC, which represents 28 state-level associations for youth-serving agencies and charities, was stuck on one key aspect of the legislation: the definition of “qualified residential treatment program,” or QRTP.
At first, NOSAC joined a major congregate care provider, Boys Town, in seeking an amendment to the bill. But now, NOSAC President Megann Anderson Fischer told YSI, “we are not seeking an amendment.”
Qualified residential treatment programs are one of three exceptions to the bill’s proposed limits on federal IV-E contributions for congregate care placements. State and county agencies may only seek IV-E reimbursement for two weeks of congregate care unless the placement is a QRTP, a placement to assist pregnant or parenting foster youth, or a setting for young adults in foster care (18 and over).
Among the specified hallmarks of a QRTP, per Family First, is the presence of nursing and clinical staff during business hours and on-call at all times.
Boys Town wants a change that requires those staff to be available “according to the trauma-informed treatment model” being used by the provider.
In a June letter to Senate and House leadership on Family First, Fischer explained NOSAC’s support for the Boys Town amendment:
While some clinicians are on-site some of the time, they are also in the community some of the time; and while they work during business hours, they also work evenings, weekends and holidays with youth and families at times that are convenient to them. Requiring a licensed clinician or nurse to be on-site during business hours severely limits the flexibility needed to provide necessary services to youth transitioning back to their families and communities.
That letter, sent on June 15, said NOSAC “cannot” support Family First without this amendment. But Fischer told YSI today the organization is no longer seeking an amendment to the bill.
“NOSAC looks forward to participating, once FFPSA is enacted, in the development of regulations that will clarify how and when nursing and clinical staff will be utilized in QRTPs to ensure effective, expeditious treatment for children and youth who need some period of residential treatment,” Fischer said, in an e-mail to YSI.
Boys Town, a Nebraska-based provider that operates in nine states and Washington, D.C., has not replied to multiple requests for comment about the Family First Prevention Services Act.
Click here to read all of The Imprint‘s continuing coverage of the Family First Prevention Services Act.