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Letter: Update on Family First Prevention Services Act

Logo of Governor's Office of Children's Initiatives
In February 2018, President Donald Trump signed the Bipartisan Budget Act of 2018, which included the Family First Prevention Services Act (FFPSA). FFPSA made historic reforms to the foster care system by prioritizing placing foster youth in home-based settings, rather than institutions. The federal law also permits children services agencies to help prevent families from entering foster care through evidence-based services, such as parenting programs and behavioral health services.

In October 2018, Ohio formed the Family First Prevention Services Act Leadership Advisory Committee to assist the state in complying with FFPSA. The Leadership Committee includes a broad base of stakeholders, such as former foster youth, families, public children services agencies, behavioral health providers, and more.

FFPSA also set rigorous quality standards for congregate care providers – or non-family based residential settings. For additional information on the definition of congregate care providers, please see Appendix A.

In partnership with the FFPSA Leadership Committee, the State has developed a timeline for ensuring that all congregate care providers serving Ohio’s foster youth become Qualified Residential Treatment Providers (QRTP), as mandated under the federal law. Beginning in October 2020, new congregate care providers in Ohio must meet federal QRTP standards to become licensed. By October 2024, all congregate care providers must meet QRTP standards.

To meet QRTP standards, a provider must:

  • Have a trauma-informed treatment model;
  • Have 24-7 access to licensed nursing staff;
  • Facilitate family engagement and outreach;
  • Ensure the provision of aftercare support for at least six months after discharge;
  • Be nationally accredited; and
  • Assess a child’s strengths and needs within 30 days of placement in their care.

In September, the United States Centers for Medicare and Medicaid Services (CMS) issued a technical assistance letter entitled “Qualified Residential Treatment Programs (QRTP) and Serious Mental Illness (SMI) and Serious Emotional Disturbance (SED) Demonstration Opportunity Technical Assistance Questions and Answers.” This letter clarified CMS’ policy regarding Institutions for Mental Diseases and its potential for impact on QRTPs, including eligibility for Medicaid reimbursement.

Over the next 22 months, the Ohio Departments of Developmental Disabilities, Education, Health, Job and Family Services, Medicaid, Mental Health and Addiction Services, and Youth Services are committed to working with providers to develop a financing model that ensures Ohio’s foster youth have access to the level of care they need, including QRTP.

Additional information on FFPSA is available at https://www.casey.org/tag/family-first-prevention-services-act/. Should you have any questions about this guidance, please contact the Ohio Department of Job and Family Services at FamilyFirst@jfs.ohio.gov.

Very respectfully yours,

Agency Director Signatures