Family First Funding FAQs

The Family First Prevention Services Act (Family First) creates an expanded entitlement/50% reimbursement of federal funds to provide services to keep children and youth safely with their families. When out-of-home placement is needed, Family First allows federal reimbursement for care in family-based settings and certain congregate care programs for children and youth.

A child is considered to be a candidate for prevention when:

1. The child is designated as being at “serious risk” of out-of home placement;
2. There is a prevention/treatment plan in place for the child and/or their family;
3. The child and/or their family is receiving an evidence-based service; and 
4. The child is residing in a “family like” setting.

Note:  The Family First Transition Act temporarily suspends the requirement that at least 50% of title IV-E prevention services expenditures be for “well-supported” practice for two fiscals years, then phases it back in as follows: 

1. In FY 2020 and FY 2021 states are not required to meet the 50 percent “well-supported” expenditures requirement (section 602(b)(1) of the Transition Act).
2. In FY 2022 and FY 2023, at least 50 percent of the amounts expended by the state for a FY for the title IV-E prevention program must be for services that meet the “supported” and/or “well-supported” practice criteria” (section 602(b)(2) of the Transition Act).
3. Beginning with FY 2024 and for all FYs going forward, states must meet the 50 percent “well-supported” expenditures requirement as described in section 474(a)(6)(A)(ii) of the Act.

Supported and well-supported services in Colorado’s prevention plan should be paid for using the Core Services Program allocation, Child Welfare Services Block, or State General Fund.

Guidelines will be developed in conjunction with the completion of Trails Modernization. Once Trails Modernization user stories are implemented for prevention services, and legacy Trails migrates to modernized Trails for both Core Services and Child Welfare Services Block, documentation can be established for best practices and communicated to Trails users. 

Four different circumstances trigger completion of the Candidacy form in Trails:

1. Creating a treatment/prevention plan (FSP3A) and adding at least one objective and candidacy screen has not been completed;
2. Doing a 90-day review (FSP5A) (unless all of the active children/youth in the case are in Out-of-Home (OOH));
3. Opening a removal; or
4. Closing a removal (except in situations where the removal closure reason is:
   • Adoption, Emancipation, Death, Transfer to DYC, or Runaway)

The Trails user stories set up prevention candidacy as an entitlement just like IV-E eligibility so that the fiscal benefits may be realized more easily.

26-5-101 C.R.S. defines Child Welfare Services and includes “Core Services,” “Early Intervention and Prevention,” as well as a number of other services. Prevention services candidacy is determined by meeting the criteria in the definition PLUS the existence of an evidence-based service. When both of these things are true, then that child or youth is a Prevention Candidate and Colorado is able to draw-down administrative costs and 50% federal reimbursement for the service costs. 

IV-E prevention candidacy and traditional IV-E candidacy are separate determinations. 

Administrative costs can be claimed for two different types of “candidacy” once Family First is implemented:

• Traditional IV-E reimbursement for administrative activities related to pursuing the removal, or providing reasonable efforts to prevent the removal, of a candidate for foster care (conditioned on a child being eligible for Title IV-E foster care). This allowable use of Title IV-E Admin will continue to be an allowable use unchanged by Family First, and 
• New IV-E reimbursement for administrative and training costs related to preventing entry into foster care for ANY child who is a “candidate for foster care” under the state’s candidacy definition 

Trails job aids and cheat sheets can be found on the Child Welfare Training System website.

Colorado will receive partial federal reimbursement under Family First for a limited set of approved evidence-based prevention programs and services included in Colorado’s Family First plan. The new federal reimbursement that Colorado receives for these programs will be claimed by CDHS, as the Title IV-E agency. Federal reimbursement for Family First prevention services will then be transferred to the Colorado Child Abuse Prevention Trust Fund. Funding will be awarded via ongoing RFPs to strategically expand evidence-based prevention services over time and build programs in areas of Colorado where they don’t already exist.

CDHS engaged the Colorado Evaluation and Action Lab at the University of Denver to develop a short and long-term strategy for expanding Family First-eligible prevention services in Colorado. Download the report.

The Division of Child Welfare Learning & Development Team is working with CDHS accounting and with the Child Welfare Training System (CWTS) to update the cost allocation methodology to draw down training dollars associated with prevention activities. These dollars will then be utilized to continually enhance CWTS offerings to achieve the Child and Family Services Plan (CFSP) goal of ensuring that Colorado has a skilled, healthy and supported child welfare workforce. 

In addition, the Learning & Development Team is working with Metropolitan State University to draw down IV-E reimbursement for activities related to the Child Welfare Stipend Program. These additional funds will also be utilized to expand post-stipend supports for stipend students entering the child welfare workforce.

There is no federal fiscal liaison. However, any fiscal questions can be directed to Division of Child Welfare Finance Manager Kelly Sawka, kelly.sawka@state.co.us.

The Colorado Department of Human Services is in the process of developing a guide associated with administrative costs to accommodate Family First. The goal is to have the guide formed, documented and communicated both internally and externally by Colorado’s Family First opt-in date, October 1, 2021.

Colorado’s federal partners have clarified that program expenditures under Medicaid for well-supported programs will not count toward the 50% requirement in section 474(a)(6)(B)(ii). Only amounts expended under the title IV-E prevention services program in section 474(a)(6)(A)(i) for the provision of title IV-E prevention services or programs that are provided in accordance with well-supported practices count toward the 50% requirement in section 474(a)(6)(A)(ii). Division of Child Welfare leadership will coordinate with the Colorado Department of Health Care Policy and Financing to discuss how we are engaging with the RAEs regarding Family First.