The Family First Prevention Services Act established a new type of residential treatment service for children with complex needs in the child welfare system called a Qualified Residential Treatment Program (QRTP). As states submit their prevention plans to the Children’s Bureau and those plans are accepted, they can begin implementing the new QRTP model in their communities, who would then be eligible for Title IV-E reimbursement.
The budget proposed a joint legislative fix between the Centers for Medicare and Medicaid Services (CMS) and Administration for Children and Families (ACF) to resolve whether QRTPs fall into the definition of a Medicaid Institutions for Mental Disease (IMD). If QRTPs are considered IMDs, any QRTP that exceeds 16 beds would be considered ineligible for Medicaid reimbursement, and the kids they are serving would also be ineligible for any Medicaid (for any type of need). This has been a question posed by many states, and last year, CMS essentially said that this interpretation would be up to state Medicaid offices. Kentucky already ruled that QRTPs qualify as IMDs, thus delaying the implementation of QRTPs in the entire state. In the budget proposal, an exemption would be created that would exempt QRTPs from the IMD exclusion, allowing children in foster care up to 18 to have Medicaid coverage in these QRTPs, even if a QRTP technically qualifies as an IMD.
Some members of Congress have already been working to address this issue through guidance, but this request from the administration suggests a legislative fix is required. The Alliance for Strong Families and Communities has been working with other state and national advocacy organizations to raise this issue and push for a legislative fix. To learn more or be involved in future advocacy efforts, email the Alliance’s Office of Public Policy and Mobilization.
A second proposal would make some changes to the title IV-E Prevention Services Clearinghouse. In this proposal, prevention services rated as promising, supported, or well-supported under the California Evidence-Based Clearinghouse or the Home Visiting Evidence of Effectiveness Project would be eligible for reimbursement, subject to ACF review. They would continue to administer the Title IV-E Prevention Services Clearinghouse to have control over the review process. Prevention services would still be defined as time-limited, evidence-based prevention services for mental health, substance abuse, and in-home parent skill-based programs for candidates for foster care, pregnant and parenting youth in foster care, and their parents and kin caregivers.
Source: Child Welfare League of America
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