CHSA submits comments about FFPSA implementation

Children’s Home Society of America (CHSA) respectfully submits the following comments per the Federal Register’s posting on June 22, 2018 Decisions Related to the Development of a Clearinghouse of Evidence-Based Practices in accordance with the Family First Prevention Services Act of 2018. CHSA, the oldest network of child-welfare agencies in the United States serving tens of thousands of children and families each year with an array of services supported by federal financial participation.  We greatly appreciate the opportunity to shape this critical component of the implementation of the Families First Prevention and Services Act. We look forward to engaging with HHS as the agency continues to develop aspects of this sweeping reform in child welfare and hope that HHS will view CHSA as a resource. 

CHSA has chosen to provide comments on sections of the proposed regulation where our expertise is most relevant.

2.2.1 Types of Programs and Services

Comment: CHSA requests that HHS utilizes broad definition of mental health services.

Rationale: Over the last several decades, our understanding of the mental health needs of children and adolescents has grown exponentially. Advances in neuroscience clearly demonstrate that the developing brain is negatively impacted when exposed to neglect, abuse, and trauma. For both children and adults, exposure to trauma often results in emotional and behavioral challenges including increased anxiety, depression, suicidality substance abuse and other compromising behaviors. The relationship between these behaviors and the underlying mental health conditions is complex and multifaceted, and interventions designed to respond to these challenges should not be unduly limited by a very narrow definition of what constitutes a mental health program.  Children and their families now defined as candidates under the FFPSA are clearly at greater risk of these mental health and behavioral challenges due to their exposure to trauma. We believe that this necessitates an array of mental health programs spanning a full spectrum of interventions. For this reason, CHSA implores HHS to adopt a broad definition of mental health programs and interventions and services required to a complete range of needs without creating new, unhelpful silos and service categories. 

Comment: CHSA requests that HHS utilizes s broad definition of substance abuse prevention and treatment services.

Rationale: We can not ignore the opioid epidemic facing our nation and the direct impact this is having on the health, safety, and well-being of children and youth. We should understand clearly the consequences of this epidemic in terms of the growth in the numbers of children entering the children welfare system due to parental addiction. Responding to this crisis will require a two generation strategy including prevention and educational opportunities targeting at-risk youth. Accordingly, CHSA respectfully requests that substance abuse prevention and treatment services are defined using broadest approach possible, minimizing the unintended consequences of programmatic and funding silos. The opioid epidemic has touched diverse communities and populations across the country. Given this diversity, it is critical that substance abuse prevention and treatment services be defined accordingly, making it possible to craft the robust solutions needed. 

Target Population of Interest (2.2.2)

Comment:  For evidence-based interventions appropriate for inclusion in the Clearinghouse, HHS should look at an expanded population of children and families similar to those in the child welfare system representing the intersectionality of children and families with underlying characteristics that place them at greater risk of child welfare involvement.

Rationale: When defining a target population for appropriate evidence-based interventions to include in the Clearinghouse, CHSA encourages HHS to look at a broad conceptualization of “similar” in order to reflect the complex needs and risks facing a wider population at greater risk of child welfare involvement. While more discreet and specific populations, such as those in the juvenile justice system might easily constitute “similar,” this would limit the inclusion of potentially robust interventions that are effective for populations with characteristics similar to those we are most familiar with.  HHS should look to other programs administered or funded through federal agencies to get a broader sense of the ecosystem where this population is overly represented due to poverty, homelessness, health and other characteristics. CHSA cautions HHS to maintain a broad lens with respect to target population when including evidenced-based interventions appropriate for the Clearinghouse.   

Trauma-Informed (2.2.7)

Comment: HHS should use “trauma-informed” as one of several criteria to prioritize programs and services for inclusion in the Clearinghouse.

Rationale:  CHSA appreciates the centrality of trauma as it relates to interventions targeting children and families considered child welfare involved.  This is a population exposed to trauma with distinct emotional and behavioral needs. Programs from across our network have increasingly reflected a trauma approach making them both more relevant and effective in delivering outcomes for children and families.  Accordingly, while CHSA supports the use of “trauma-informed” in the agency’s consideration of interventions for prioritization, we requests that HHS note and allow for the reality that a number of successful interventions do not formally include the specific terminology “trauma-informed.” CHSA suggests HHS utilize “trauma-informed” as one but not the exclusive criteria for prioritizing programs. 

Target Outcomes (2.2.3 )

Comment: While this section does include reference to outcomes that prevent child abuse and neglect, reduce the likelihood of foster care placement by supporting birth parents and kinship families, the Federal Register notice requests comment on target outcomes on prevention services but not on Kinship Navigator services. This is a significant omission. The statement the “HHS does not intend to include access to service, satisfaction with programs and services, and referral to programs and services as `target outcomes'” is specifically contrary to Kinship Navigator services as states in section 427(a)(1) of the Social Security Act.

This section on Target Outcomes should specify that this comment refers to prevention services and does not apply to Kinship Navigator activities. There should be a separate discussion of target outcomes related to Kinship Navigator activities. Consideration should include activities that improve access to services, and referral to programs and services. These are integral to an effective Kinship Navigator program. Evidence-based programs related to Kinship Navigator should included consideration of research related to the Supplemental Nutrition Assistance Program (SNAP) and health-related programs that have found that participation in these programs improve child well-being.

Dan Spence