The major provisions of the Family First Prevention Services Act – the allowance of Title IV-E entitlement funds for front-end services meant to prevent the use of foster care in some cases, and limitations on IV-E funds for congregate care placements – don’t kick in until October of 2019, at least for states that opt to participate.
But the Administration for Children and Families (ACF), the division of the Department of Health and Human Services (HHS) that oversees child welfare, has a shorter timeline for its part in the process. The law requires the agency to build an evidence-based clearinghouse of programs and models that are cleared for funding under Family First’s front-end section.
HHS is now looking for people in the research and policy realms to weigh in on how the clearinghouse should prioritize its review process, and what programs should be considered for inclusion. The notice, which was published in the Federal Register, also sheds some light on how the agency is thinking about structuring the clearinghouse. (You can click here for a full guide to the many parts of Family First, including the clearinghouse.)
In a nutshell, as far as the clearinghouse goes, ACF must offer a list of programs and service delivery models that are rated as “promising practice,” “supported practice” or “well-supported practice.”
Those determinations will be based on evidence of the program’s impact from rigorous evaluations, preferably randomized control studies. The top classification, “well-supported,” are programs that demonstrate impact over a long period of time.
The clearinghouse will focus on programs that align with the three specified interventions included in Family First: substance abuse services, mental health treatment and parenting skills development.
This construct is a major factor in the implementation of the law. States can only tap into the new IV-E front end to pay for programs that appear on this list, so the menu options that are deemed allowable will be of great interest to state agencies.
The notice asks for recommendations on which programs should be included in the clearinghouse, an open invitation to make possible programs known to ACF. This had already been encouraged of county child welfare agencies by some of Family First’s Congressional architects, on an April webinar hosted by the National Association of Counties.
ACF also had some research-oriented questions about how to approach decision-making about what should go into the clearinghouse. Following are a few of the specific issues ACF has asked for input on.
Family First was prescriptive in limiting the front-end services to programs with an evidence base, but the law deferred to the executive branch to decide what it wanted evidence of. The notice asks the public to weigh in on “which types of mental health, substance abuse, and child and family outcomes should be considered as ‘target outcomes’” for programs included in the clearinghouse.
The notice also makes clear a few outcomes that ACF does not intend to consider in its decision-making: “access to service, satisfaction with programs and services, and referral to programs.” The message there is pretty clear: inclusion will require a demonstration of the services working, not just that they were delivered or appreciated.
This is an aspect of the process that will have a huge impact on the clearinghouse. A narrow scope of outcomes might just include child welfare-related things, like future reports of maltreatment or placements into foster care. A broader range of outcomes could include things related to the efficacy of the treatment on the adult: relapse rates, or future occurrence of mental health episodes.
Ensuring Study Quality
ACF asks for opinion on what the thresholds should be for rating the quality of study design, analysis and outcome measure validity.
It also states an intention to prioritize the review of programs “that have been developed or used to target children and families involved in the child welfare system or populations similar to those involved in the child welfare system.” ACF wants public opinion on how it should define “similar” in that phrase; what populations are comparable, for the purposes of evaluation and evidence, to families in contact with the child welfare system?
The Family First Act only allows IV-E funding to be used for the front-end services for up to 12 months. ACF asks if the clearinghouse should only include programs with implementation windows of 12 months or less, or include options that states and counties might have to pay for without federal funds after a year?
The Family First Act requires that all of the front-end options should come “under an organizational structure and treatment framework that involves understanding, recognizing and responding to the effects of all types of trauma and in accordance with recognized principles of a trauma-informed approach and trauma-specific interventions to address trauma’s consequences and facilitate healing.”
ACF asks for comment on “the feasibility” of that standard. Youth Services Insider’s read of that isn’t that the agency is necessarily hostile to the requirement, but might want to lock in a definition of what it actually means to be “trauma-informed.”
The deadline to supply ACF with comments is July 22.
YSI’s bet would be that the clearinghouse will not be fully completed on time. ACF spokeswoman Monique Richards told YSI that the plan is to “solicit a contract to establish and maintain a clearinghouse of Family First Prevention services though HHS’ Procurement Forecast Data Repository site.”
ACF is hoping to ink that contract by “late September 2018,” according to Richards. The contract will likely be in the neighborhood of $1 million per year, since that is what the Family First Act allocated to operate the clearinghouse.
In light of the short timeline to develop the clearinghouse, the notice provides some insight into what types of programs ACF will prioritize for review. Here are a few of the intended priority criteria included in the notice:
- At least two studies with different samples.
- Actively in use somewhere in the United States.
- Presence of fidelity monitoring tools and resources, as well as national training centers that can assist systems with implementation.
- For the parenting skills portion, programs that deliver services in the home.