Essential reading: what are the currently unspoken potential consequences of government Family First plans for Residential Child Care?

3 Questions

1. Has anyone noticed we are being led down an American pathway?
2. Why has none of the following been raised in Parliamentary scrutiny?
3. Are there other voices than NCERCC in the Residential Child Care sector raising these important issues?

1. It can happen here – in the USA, a 25% decline in Residential Child Care placements.

Following the Family First Prevention Services Act (FFPSA) there has been a 25% decline in the preference for residential child care placements.

This is a significant shift prioritising family-based placements and preventing the need for children to enter residential settings.

The US Family First legislation mandates that children be placed in the most family-like setting possible and has led to a decrease in ‘congregate’ care, where children live in group care settings.

Sound familiar?

Let’s look further.

Essential reading for all Residential Child Care providers

2. Restrictions on Reimbursement for Non-Therapeutic Residential Care (Qualified Residential Treatment Programmes, or QRTPs)

Does the current English questioning of the term ‘therapeutic’ need to be understood in this context?

If you are ‘therapeutic’ or not there are serious implications to be noted.

The FFPSA significantly limits federal reimbursement under Title IV-E, the principal source of funding for child welfare, for children placed in residential care settings. After two weeks in such a setting, federal funds are available only if the placement is in a QRTP, which must:

• use a trauma-informed treatment model; (England has used few treatment models)
• be staffed by licensed clinical personnel; (meaning Residential Child Care workers)
• engage family members in the child’s treatment; (meaning local) and
• provide aftercare services for six months, post-discharge. (meaning local, meaning more than Supported Accommodation)

Although Family First’s goals are widely embraced, state implementation of the law has varied widely and has been complicated by operational, fiscal, and systemic challenges, including:

• recruiting and retaining appropriately licensed and trained clinicians (residential child care workers), both to meet QRTP standards and to implement evidence-based prevention services. A challenge to all Residential Child Care providers.
• the philosophical change from a placement-focused system to one that is prevention-focused. Shifting mindsets requires sustained training, communication, and leadership commitment. In the English legislation there is nothing on this at all. A challenge to national and local government.

Many states have reported difficulties in meeting QRTP standards,

• assessments are not completed timely
• QRTPs do not have adequate staff training, quality and capacity
• Aftercare is not suited to the child’s needs

The American Academy of Paediatrics have expressed their concerns about the quality of treatment offered by QRTPs, as follows

“ the use of QRTPS as an individualised and quality treatment intervention, as opposed to a standardised placement, has yet to be realised. Concerns about the accountability quality, and sustainability of the QRTP workforce stymy the implementation of individualised, trauma-informed treatment.”

The move to group care being Qualified Residential Treatment Programmes has proven been logistically and politically complex.

Many residential care providers have expressed concern about transitioning or declined to attempt it, fearing financial instability or closure.

Many providers have argued that the cost associated with certification to become a QRTP is prohibitive; programmes must meet clinical staffing requirements, undergo third-party assessments, and involve family engagement, all of which are resource intensive.

Due to these challenges, many states report insufficient or reduced placement capacity (or both), particularly among high-need youth.

Noteworthy

• the limited number of programmes in the Title IV-E Clearinghouse;
• the high standards for the “evidence-based” designation that exclude some programmes considered locally effective;
• the difficulty in building the infrastructure (e.g., data systems and evaluation capacity) to deliver and measure these services effectively; and
• insufficient infrastructure to deliver evidence-based prevention services at scale.