Child Welfare Placement Continuum

Introduction

Family First is aligned with the progress Colorado is already making to reduce the use of out-of-home placements for children and youth involved in the child welfare system. Children and youth should, whenever possible, be placed in the home with family and/or kin with access to in-home services that prevent out-of-home placement. Only when out-of-home placement is the most appropriate option, children and youth whenever possible, should be placed: in their communities, in culturally-reflective homes, in the most family-like settings, in treatment-focused settings when appropriate, and always in the least restrictive placement setting.

At a Glance

What County Directors Need to Know

  • Federal Financing for Congregate Care Placements
  • Specialized Settings
  • Supporting Kin
  • Family-like Placements in the Community
  • Qualified Residential Treatment Programs (QRTPs)
  • HCPF Policy for Residential Providers
  • Psychiatric Residential Treatment Facilities (PRTFs)
  • Family First Transition Funding
  • Funding Options for Residential Treatment
  • Independent Assessment Process for QRTP Placement

Action Items

  • Meet with partners on the local level
  • Prepare your county for the independent assessment process

What County Directors Need to Know

Federal Financing for Congregate Care Placements

Family First changes federal funding for placement reimbursement. Placement in Residential Child Care Facilities, group homes, and group centers are longer eligible for federal reimbursement beyond 14 days, unless they are licensed and accredited as Qualified Residential Treatment Programs (QRTPs) or serve designated “carve-out” populations. This CDHS Operation Memo (OM-CW-2021-0015) offers further guidance about processes to operationalize congregate care provisions of the law.

Specialized Settings

Family First allows for federal reimbursement of specific congregate care settings for certain populations, sometimes called “carve-out populations:” These specialized group settings include programs for youth at risk of or survivors of trafficking; prenatal or parenting youth; and youth 18 years of age or older living independently with supervision. This CDHS Operation Memo (OM-CW-2021-0016) offers further guidance about the standards for operating programs that provide specialized services to pregnant and/or parenting children/youth, children/youth who are survivors of sex trafficking or children/youth who are at risk of being trafficked. New rules for specialized settings have not yet been approved by the State Board.

Supporting Kin
  • Supporting Kin: Family First further supports increased utilization of kinship families and reimburses for some Kinship Navigator Program services. We know that permanent or temporary placements with kin help maintain familial relationships and cultural connections, support parent reunification efforts, and often prevent further trauma and result in better outcomes for children and youth when they aren’t able to remain safely in the home. Additional information on efforts to support kinship caregivers:

    • Foster Source is a nonprofit organization offering trauma education, relief services and therapeutic services to foster and kinship families throughout Colorado. They are also working on a database called “Respite Source” to connect families with respite options. 

    • CHAMPS Colorado strives to ensure vulnerable kids are safe and thriving by promoting foster and kin families as a vital component of the child welfare system. They launched in May 2020 in partnership with Foster Source and are part of a national campaign to ensure quality parenting for all children in foster care. CHAMPS is engaging with CDHS to provide a foster and kin family voice in the implementation of child welfare policies. On the county level, CHAMPS is working in several pilot counties to improve programs for foster and kin families to ultimately increase retention rates.

    • The Kinship Foster Taskforce has been established to discuss changes to statute and rule to reduce barriers for kin to become certified foster care providers and establish practices that better support kinship care. 

    • In addition, Colorado’s Juvenile Justice Reform Bill (SB19-108) requires identification of kin for supports and placement purposes. In delinquency court cases, support is allowed for kinship providers.

Family-Like Placements in the Community

Colorado needs foster families that can effectively serve higher acuity children and youth, who historically have been placed in congregate care settings. While treatment foster care currently exists in a very limited capacity in the state, therapeutic foster care is a new level of care in Colorado. Effective July 1, 2021, new rates have been developed for Treatment Foster Care and Therapeutic Foster Care placements (IM-CW-2021-0035). Child maintenance rates were also updated effective July 1, 2021 and include respite and foster parents support costs. The Foster Care Placement Continuum Task Group is examining historical barriers contributing to the lack of treatment foster homes and creating a recruitment strategy for therapeutic foster homes. CDHS has developed a set of key strategies, based on stakeholder input, for rightsizing and refining the placement continuum.

Qualified Residential Treatment Programs (QRTPs)

Family First creates a new short-term, high-quality, treatment-centered level of care called Qualified Residential Treatment Programs (QRTPs). QRTPs can be used for placement only when a child’s or youth’s behavioral health treatment needs cannot be met with any other lower level of care. QRTPs must have a trauma-informed treatment model, have registered or licensed nursing and other clinical staff available 24/7, be licensed by the state, and be nationally accredited. QRTPs should NOT be used for containment purposes or due to a lack of other placement options. To place a child or youth in a QRTP, the county child welfare agency must request an independent assessment by a qualified individual before or upon admission to a QRTP.

 QRTP basics

HCPF Policy for Residential Providers

The Department of Health Care Policy & Financing (HCPF) has updated their draft policy regarding child- and youth-serving residential treatment facilities. The only provider types that will be reimbursed by Medicaid after June 30, 2022, when HCPF’s residential policy is fully implemented, are QRTPs and PRTFs. The two exceptions to this policy are: CHRP providers and SUD providers. This policy addresses the Institution for Mental Disease (IMD) considerations under Medicaid so the state can move forward with residential facilities in alignment with Medicaid and new Title IV-E provisions of Family First. The new policy outlines that Medicaid reimbursement will be available for medically necessary stays in treatment facilities of 16 beds or fewer and provides further guidance on the transition for providers. This policy will go into effect no later than Oct 1, 2021 in order to allow QRTPs to enroll in Medicaid as a new provider type as required by Family First. However, there is an extended transition period up to June 30, 2022 for remaining providers/facilities to meet the guidelines of this policy. All facilities enrolling in Medicaid must complete HCPF’s attestation form to demonstrate compliance with the new policy.

Psychiatric Residential Treatment Facilities (PRTFs)

Beyond QRTP level of care, are there other options for a higher level of care? A Psychiatric Residential Treatment Facility (PRTF) is a higher level of care than a QRTP and operates primarily from a medical approach for higher acuity mental health conditions that may require stabilization efforts, medication management, and care for physical risk factors (i.e. self-harm, aggression, etc.). It is a non-hospital facility with a provider agreement with a State Medicaid Agency to provide the inpatient services benefit to Medicaid-eligible individuals under the age of 21. CDHS has created a reference guide that details differences between RCCF-QRTP, RCCF Non-QRTP, and PRTF levels of care. There is a long version of the resource and an executive summary version available. In addition, HCPF created a draft  PRTF Q&A factsheet which attempts to answer some of the policy, process, and financing questions to accessing and utilizing this level of care.Questions around and barriers to accessing this level of care in Colorado started surfacing in 2021 when talking about the placement continuum. As of early 2021 there were only two active PRTFs in the state of Colorado, which were primarily serving out of state residents. Colorado needs facilities that can meet the need of Colorado’s residents programmatically through appropriate staffing, expertise, and treatment. HCPF is working to address barriers to PRTF utilization on the practice side, including improving the process to incentivize in-state placement needs, as well as, improving actual practice with existing providers. Effective July 1, 2021 the PRTF rate was increased to $750 per day (HCPF Provider Bulletin). View the facilities that are currently pursuing or already have a PRTF license

Family First Transition Funding

SB21-278 required that CDHS assist residential placement providers in transitioning to models that are Title IV-E and medicaid eligible with Colorado Transition Act funding. About $1.1 million of the state’s transition funds were awarded in grants to providers. A separate solicitation for efforts focused on building a comprehensive continuum of placement options across the state was awarded in 2021. The opportunity included efforts to serve high acuity youth in family-like settings; recruitment and retention of therapeutic and treatment foster homes; enhanced supports for foster parents and kinship families; and efforts to better understand and respond to the needs of Colorado’s children and youth in all types of care. More details about awardees can be viewed on this page.

Funding Options for Residential Treatment

This flowchart created by the Colorado Department of Human Services provides county child welfare agencies guidance regarding obtaining funding and approval for residential treatment for children and youth.

Independent Assessment Process for QRTP Placement

Action Items

Meet with partners on the local level
  • Talk to your local providers that will no longer meet federal criteria for placement reimbursement about the future continuum and what placement types you anticipate needing to build for the children and youth in your community. For those interested in transitioning to a QRTP, CDHS licensing staff are providing one-on-one coaching, transition planning and technical assistance to facilities that are applying to become a QRTP and/or need to adapt their business model.
  • Conversations around Family First implementation and collaborative decision-making should happen at multiple levels. If you haven’t already, reach out to your local bench, legal partners, Best Practice Court Team, Juvenile Services Planning Committee, and Collaborative Management Program partners, to see what they know about Family First, how it will impact placement in your community, how it intersects with detention reform, and how it will impact the court’s role. Provide your perspective, ask questions, and emphasize what you think they need to know as it relates to being prepared for family first implementation in your community. Supplemental resources from ABA Center on Children and the Law: Tool for Agency Leadership: Engaging the Legal Community in Implementing Family First; The Family First Prevention Services Act of 2018: A Guide for the Legal  Community
  • Bring the Administrative Service Organization in your region into local conversations.

    Beacon Health Options

    Elizabeth.Richards@beaconhealthoptions.com, 719-367-7164

    Cheyenne, El Paso, Kit Carson, Lincoln, Logan, Morgan, Park, Phillips, Sedgwick, Teller, Washington, Yuma

    Beacon Health Options for Health Colorado

    Elizabeth.Richards@beaconhealthoptions.com, 719-367-7164

    Alamosa, Baca, Bent, Chaffee, Conejos, Costilla, Crowley, Custer, Fremont, Huerfano, Kiowa, Lake, Las Animas, Mineral, Otero, Prower, Pueblo, Rio Grande, Saguache

    Rocky Mountain Health Plans

    Krista.Cavataio@rmhp.org

    Archuleta, Delta, Dolores, Eagle, Garfield, Grand, Gunnison, Hinsdale, Jackson, La Plata, Larimer, Mesa, Moffat, Montezuma, Montrose, Ouray, Pitkin, Rio Blanco, Routt, San Juan, San Miguel, Summit

    Signal Behavioral Health

     Bret Snyder bsnyder@signalbhn.org, 720-617-9723

    Adams, Arapahoe, Boulder, Broomfield, Clear Creek, Denver, Elbert, Gilpin

  • Mirror state conversations on the local level to assess barriers and support solutions for the future placement continuum, including, treatment and therapeutic foster care options and QRTPs. Participate in ongoing state-led conversations around expansion of the placement continuum.
Prepare your county for the Independent Assessment process
  • Access the Family First Independent Assessment toolkit on the independent assessment process: The toolkit includes an introduction to the required steps in the Independent Assessment process from the county’s perspective; mock independent assessments, referral face sheets, court reports, process maps, fact sheets and training guides.
  • What do caseworkers and supervisors need to know about the independent assessment process? CDHS has developed and is refining training on the independent assessment process and the CANS tool that your staff will be able to access. Prior to this training, you can prepare your child welfare staff by discussing their role in requesting the initial referral for and engaging throughout the independent assessment process when QRTP might be a good fit and how case planning may look different. Manage expectations that the independent assessment involves a tight timeline. This is a new process and it will take some time to adjust to all the steps. Caseworkers will be critical in:
    • Requesting the initial referral for the independent assessment process when QRTP might be a good fit for a child/youth,
    • Notifying, scheduling, coordinating, and facilitating all parties regarding the Family and Permanency meetings,
    • Ensuring proper documentation, and
    • Generating and submitting the Child Welfare Court Report.
  • Have local conversations with your Administrative Service Organization, RAE, CYMHTA, and court/legal partners.
  • Watch the Division of Child Welfare Town Hall about the different assessment processes for the Children and Youth Mental Health Treatment Act (CYMHTA) and the independent assessment process for QRTP placement

CDHS logoCHDS logo Colorado's Family First Implementation Guide for County Directors is a collaboration between the Colorado Department of Human Services and the Colorado Human Services Directors Association.