Colorado Family First Implementation Dashboard
The Family First Prevention Services Act (Family First) is the most significant change to child welfare in decades. For the first time, federal funding can be accessed for prevention services that keep kids safe, growing up with their families. If staying home safely is not possible, Family First encourages care in a family-like setting or, if necessary for a short time period, care in a congregate setting designed to meet specialized treatment needs.
Colorado must comply with specific federal Family First requirements by October 2021. Additionally, Family First is one piece of a broader Colorado vision to evolve the child welfare system to serve children, youth and families together.
Implementation will occur alongside other system reforms and our ongoing work with children, youth and families.
Successful implementation will require strong and sustained partnerships among multiple stakeholders.
Implementation is a long-term, iterative process. There is no flip-the-switch moment when implementation is complete.
Through implementation of Family First, Colorado strives to improve policy, practice and quality of services in order to support community, culture, diversity, equity and access for all Coloradans across the state. See the full commitment statement here.
FAMILY FIRST IMPLEMENTATION DASHBOARD
SHORT TERM: FEDERAL COMPLIANCE
To comply with Federal Law, the State of Colorado must have the following in place:
QRTP rules have been drafted and an application process has been developed to support this new Family First-eligible licensing designation. Final QRTP rules (7.705) went to the State Board of Human Services in July 2021, and will be effective October 1, 2021.
Links: QRTP fact sheet, QRTP Resource Page.
CDHS-Office of Behavioral Health developed Colorado’s trauma-informed care model for QRTPs and will approve each facility’s plan as part of the QRTP application process.
Links: QRTP resource page, QRTP Trauma-Informed Care Model
Rules have gone into effect as of June 1, 2021. Confirming guidance from the federal government regarding immunization and any needed changes to Colorado rule.
Link: Revised rule.
Colorado has added extended foster care up to age 21 in its Title IV-E plan since early 2018. This change allows Colorado to access Chafee expansion up to age 23. Colorado is now in the process of ensuring implementation is consistent and supported throughout the state.
MEDIUM TERM: STATE-LEVEL GOALS
Colorado’s vision is to leverage Family First for sustainable system reform, not just compliance:
Opt-In to Prevention Services:
An approved plan will allow Colorado to begin drawing down federal reimbursement for eligible services. Federal feedback was received on Colorado’s first draft plan, and the next version is in development.
Status: Final plan, submitted on September 30, 2021, is awaiting final approval from the federal government.
State-level infrastructure to meet federal requirements and claim reimbursement
Fiscal and data systems are in place to track and claim federal reimbursement. Family First fiscal claiming group has completed its work.
Update: Colorado is in the process of designing and developing a statewide CQI Platform.
Link: Claiming under Family First training series
Colorado is in the process of using a data-informed process to develop a short, medium and long-term strategy for prevention services expansion statewide.
Video: Mental health service array information sessions
Link: Strategy for the Evidence-Based Aspects of the Family First Service Continuum
Expand Family First-Eligible Placement Options:
IMD Issue Resolution and Policy Implementation (HCPF)
The federal law governing Institutions for Mental Diseases (IMD) was considered a major barrier to implementation. The Colorado Department of Health Care Policy and Financing (HCPF) has developed additional clarification and draft policy to minimize impact to Colorado’s placement continuum. Rule changes and implementation infrastructure are in development
Link: QRTP/IMD information and fact sheet.
Update: Rule has passed Medical Services Board (MSB) and awaiting CMS approval.
Guidance/rule for serving specialized populations
Eligibility criteria for youth victims of sex-trafficking and for pregnant and parenting youth to be served in residential care settings outside of QRTPs have been developed. Parameters for programs specializing in the care of youth victims of sex-trafficking have also been developed. Any parameters that are going into rule will go to the State Board of Human Services in July 2021.
Link: Download draft rules
Update: Rules drafted and pending approval at State Human Services Board by February 2022. Operation memo with rule and guidance to be issued before October 1, 2021.
Placement continuum strategy
CDHS has developed a set of key strategies, based on stakeholder input, for rightsizing and refining the placement continuum.
Independent assessment process for counties
Dark blue: Prepared for independent assessment
Link: Independent Assessment county cohorts.
LONG TERM: SYSTEM TRANSFORMATION
Implementation is a long-term, iterative process
Family First will be leveraged as one of many strategies to achieve the state’s long-term goals:
Moving from a reactive child protection system to a proactive child and family well-being system
Prioritizing and incentivizing expansion of community-based prevention-focused services and dramatically reducing the need for out of home care
Building a robust continuum of care that is responsive to the needs of children, youth and families