Opportunities in California’s Implementation of the Family First Prevention Services Act

Many families who become involved with child protective services (CPS) have experienced systemic and structural barriers that impact access to supportive services. Some children and families only receive supports after they’ve become CPS-involved. By that point, however, a traumatic event—such as maltreatment or family separation—has already occurred. Early childhood trauma is particularly concerning because of how rapidly children’s brains are developing in this early period. Providing supportive services early and before a family becomes CPS-involved is critical to prevent and mitigate the negative impacts of trauma.

The Family First Prevention Services Act is a significant reform to child welfare services, allowing agencies to use federal child welfare funding to cover the costs of upstream, prevention-focused services for families at risk. The funding may be used for in-home parent skill-based programs, mental health services, and substance abuse treatment with the goal of strengthening families and keeping children from entering foster care. Here, we break down some important parts of the law and its implementation in California to help early childhood leaders understand what the opportunities are.

To draw down Title IV-E funding for prevention services, local child welfare agencies must meet federal requirements. Significantly, IV-E funding only reimburses services to families with children who are at “imminent risk” of entering foster care. This means that federal reimbursement can only be used for some activities falling under secondary prevention (programs targeted at families in need to prevent escalation) and tertiary prevention (interventions for children experiencing maltreatment). Federal reimbursement does not cover primary prevention activities (programs targeted at the entire population in order to provide support before problems occur). Prevention services must be evidence-based, according to the federal Title IV-E Prevention Services Clearinghouse. Additionally, the federal statute names IV-E funding as the payer of last resort. This means that IV-E funding can only be used to cover evidence-based practice (EBP) activities that cannot be funded with other programs, like Medicaid.

As described in the Five-Year State Prevention Plan, California’s implementation of FFPSA will go further than outlined by the new federal law. By contributing other funding sources, California IV-E agencies will be able to offer more families a fuller array of services - including home visiting- and create a comprehensive prevention continuum inclusive of primary prevention strategies. The new state and federal program will have several features that family serving agencies should know about.

First, implementing IV-E agencies are asked to provide a community pathway, which allows eligible families to voluntarily seek services without the stigma attached with direct involvement with child welfare. In a community pathway, the lead agency conducting assessments and coordinating services for the family is a community-based organization (CBO) or Family Resource Center (FRC) contracted by the IV-E agency.

Second, full implementation of FFPSA involves the development of a statewide data system to collect federally required data. Data systems are necessary to enable counties to begin claiming and draw down the correct federal funding. However, this process is complex and still underway. The California Department of Social Services (CDSS) has not yet indicated when this data system will be fully implemented.

Third, funding is flowing in the interim to assist IV-E agencies in developing their local Comprehensive Prevention Plans (CPP). These are currently due January 2023 and pose opportunities for partners to get involved. Significantly, CPPs require cross-sector collaboration and community needs assessments, which should include information about target populations and EBPs counties plan to scale. Funds can also be used to support primary prevention activities and the evaluation of EBPs and culturally-responsive services to build evidence to support future inclusion in the Clearinghouse. While 10 well-supported EBPs are currently included in California’s Five-Year Prevention Plan, the CDSS has identified an amendment process to add future EBPs. CPP templates are forthcoming.

First 5s and their partners can be powerful contributors to the expansion of these family support services under FFPSA. Deeply familiar with local FRCs and CBOs, First 5s can support the braiding of this new IV-E funding with existing funding to expand prevention services for more families within their counties. Moreover, CPP planning resources specifically name First 5s as partners in this work. First 5s would be valuable assets, as many have existing cross-sector partnerships and are attuned to local needs.

To stay up-to-date on the latest information about California’s FFFPSA implementation, sign up for the CDSS email listserv. While there are plans to roll out a website dedicated to California’s FFPSA implementation, the launch date is not public. For now, be on the lookout for updates included in All County Letters posted on the CDSS FFPSA homepage.