In this video, Jennifer lists a few examples of how you can involve and update community stakeholders throughout the accreditation process.
Time is Tight: Seek Accreditation Now for QRTPs [as Mandated by the Family First Prevention Services Act]
The new Family First Prevention Services Act (FFPSA) has generated many questions about the timing of when each state will decide to implement the regulations and, in turn, when the new category of residential settings called Qualified Residential Treatment Programs (QRTPs) are required to become nationally accredited. Accreditation for qualified residential treatment programs has thus become a hot topic for such centers.
FFPSA is changing the face of child welfare by authorizing federal dollars to support prevention services for children identified as being in “imminent risk” of entering foster care. It also shifts the focus from relying on congregate or group care settings to keeping children in family-like atmospheres – specifically foster family homes.
Under FFPSA, with limited exceptions, states will be able to dedicate federal Title IV-E funding for children’s care maintenance payments in a residential setting after the first two weeks of placement. Approved settings, including the new QRTPs, must use a trauma-informed treatment model and employ registered or licensed nursing staff and other licensed clinical staff who are onsite according to the treatment model and available 24 hours a day and seven days a week.
The law institutes other requirements related to formal assessments of children that ensure the appropriateness of the placement, family engagement and aftercare support for at least six months post-discharge. For additional information, visit: http://www.ncsl.org/research/human-services/family-first-prevention-services-act-ffpsa.aspx
States’ Decisions – To Delay or Not Delay?
FFPSA specifies that to be considered as an official QRTP, the program must be licensed and accredited by a Department of Health and Human Services-approved accreditation agency: Commission on Accreditation of Rehabilitation Facilities (CARF), Joint Commission on Accreditation of Healthcare Organizations or Council on Accreditation (COA) by October 1, 2019, unless a state requests a delay for up to two years.
States are presently weighing their options to request a delay or “opt-in” to comply with the new restrictions regarding reimbursement. States must submit their request to the HHS Children’s Bureau by November 9, 2018 if they intend to delay the effective dates of certain provisions in the Family First act. However, states may still change their decision after their plan has been submitted, so nothing is definitive at this point – except that QRTPs will need to become accredited.
A number of service providers are opting to wait and see if their state will delay the effective dates with the hope that this will provide additional time to become nationally accredited. However, a delay in accreditation for qualified residential treatment programs is a gamble on the service provider’s future.
“I recommend that non-family-based care providers like group homes or residential programs who wish to become a licensed QRTP, begin the process of accreditation now,” said Leslie Ellis-Lang, Managing Director, Child and Youth Services at CARF. “It is the safest action.”
Accreditation for Qualified Residential Treatment Programs
Most service providers require 12 to 18 months or more to become nationally accredited. With the initial effective date of October 1, 2019 one year away (unless a state delays enactment), there is still some time to complete the process.
To meet the FFPSA deadline, organizations must consider the time necessary to:
- Select an accrediting body
- Secure budgetary allotment and board approval
- Develop accreditation-required plans, including an organization-wide strategic plan, among others
- Prepare standards-compliant policies, procedures and protocols
- Implement accreditation standards (both CARF and COA require six months of conformance with standards before an onsite survey may take place; Joint Commission does not require this “look back”)
- Make operational, service delivery and facilities improvements, as necessary
- Prepare staff and board members for the accrediting body’s onsite survey
Accreditors’ Efforts and Deadlines
Under such a sweeping federal mandate as FFPSA, thousands of organizations throughout the United States will apply for accreditation at the same time, which can strain the capacity of the accrediting bodies.
The good news is that each of the three (presently) approved agencies (CARF, COA, Joint Commission) have been proactively preparing for this onslaught of new applicants by increasing their operational staff and adding surveyors to conduct the onsite reviews.
Yet each accrediting body has its own timeline, based on when applications are due and the scheduling of onsite surveys. Regardless of which body is selected, an organization should generally estimate that it will take at least 12 months to achieve accreditation.
In order to complete the process and receive accreditation by October 1, 2019, organizations must submit their application and deposit by the following deadlines:
CARF:
CARF recommends that organizations choosing to use the 2018 Child and Youth standards for their survey and wanting to be notified of their outcome prior to October 1, 2019, should submit their application by December 31, 2018.
COA:
COA’s application deadline for organizations working toward the October 1, 2019 benchmark is November 19, 2018.
Also, in October 2018, COA will provide an application fee refund (in the form of a credit against future fees) for organizations that are mandated by FFPSA and are pursuing accreditation for the first time. An organization must complete its initial application by October 3 and fully execute an accreditation agreement by October 31, 2018 in order to receive this benefit.
The Joint Commission:
To complete the accreditation process and receive a Joint Commission accreditation award by October 1, 2019, organizations are “strongly encouraged” to submit an application and deposit by December 31, 2018 with a request for onsite survey (“ready date”) of no later than April 1, 2019.
Regardless if a state decides to opt-in or delay the FFPSA regulation and requirement for QRTPs, all service providers are strongly encouraged to begin the road to national accreditation as soon as possible. No matter what a particular state decides to do, the mandate is here to stay. Don’t gamble on your organization’s future!
Accreditation Guru is available to assist in the accreditation for qualified residential treatment programs, child welfare and behavioral healthcare organizations nationwide as they navigate the road to accreditation in an efficient and streamlined manner. For more information, contact us at Info@AccreditationGuru.com.
Accreditation Mandate? Panic or Plan!
Accreditation mandates are all the talk among leaders of human service organizations. Thanks to the recent passage of the Family First Prevention Services Act (FFPSA) on the national level and state mandates for accreditation, like one recently instituted for adult foster care providers in Massachusetts, many child, family and behavioral healthcare service agencies are becoming alarmed about having to complete the complex accreditation process within short deadlines. Well, they can either panic or plan!
Accreditation requires that organizations undergo an objective review by an independent accrediting body and signifies that they are effectively managing their resources and enhancing the quality of life for the population served. Providers that earn accreditation signal their desire to reach beyond the minimum licensing standards and make a long-term commitment to strong governance, program consistency, outcome measurement and continuous improvement throughout their agencies.
Achieving accreditation is a worthy endeavor, even if it is a requirement, but many organizations underestimate the time commitment involved. In general, it takes 12 to 18 months to prepare for national accreditation – sometimes more, sometimes less, depending on the original state of readiness.
Effective project management from the beginning is key. You must plan for an even flow of work in order to avoid a rush at the end. You also need to allow time for significant steps in the process, including, but not limited to:
- Selecting an accrediting body. (See our tip sheet on how best to approach this evaluation.)
- Securing budgetary allotment and board approval.
- Each accrediting body calculates its own application fees, survey costs and annual fees, which may vary widely based on the revenue size of the organization being reviewed, and/or the number of programs and locations. Staff time, operational improvements and consultants (if utilized) may also add to overall expenditures.
- Preparing standards-compliant policies, procedures, plans and protocols.
- Making operational and service delivery improvements, as necessary.
- Implementing updated processes to conform with accreditation standards.
- Participating in a mock survey.
When an accreditation mandate is enacted, a deadline is imposed on organizations. Remember, though, that there may be hundreds or many hundreds of organizations trying to become accredited at the same time and the accrediting bodies only have a finite amount of capacity to accommodate all of these applicants.
With the Family First Prevention Services Act, for example, congregate care providers must become accredited “Qualified Residential Treatment Providers” (QRTPs) by October 1, 2019. Though states have the option to extend this deadline for up to two years, all affected service providers should already be proactively working toward accreditation.
When a mandate is instituted, impacted organizations should begin the accreditation process as soon as possible to get ahead of the influx of other providers seeking to become accredited and have enough time to thoroughly and calmly complete the necessary work. Once the process begins, effective project management and support from leadership will help ensure that accreditation activities stay on track despite other priorities that may arise.
Clearly, it is better to plan rather than panic!
Accreditation Mandate for QRTPs Under FFPSA: Start the Process Now!
When it passed the Family First Prevention Services Act (FFPSA) last February, Congress aimed to change the face of child welfare, in part by implementing a funding shift that restricts the use of Title IV-E financing for out-of-home “congregate care” placements. The goal is to increase assurances that children will be kept in family-like settings whenever possible.
One section of FFPSA defines a Qualified Residential Treatment Program (QRTP), which is one of the few settings that will be allowed to receive federal reimbursements after the first two weeks a child has been in care.
A key provision of the Act is that QRTPs must be accredited by a national organization. This is a long process that should be undertaken as soon as possible because time to comply with the act is running out. Do not underestimate the effort it takes to achieve national accreditation. The time to begin the process is now.
Congregate care providers must become QRTPs by October 1, 2019 if they want to be eligible for this designation. While states have the option to extend this deadline for up to two years, all providers should be working toward next year’s October 1 deadline.
What does it mean to become a QRTP? In summary, the service provider must:
- Be licensed and be accredited by at least one of three federally approved accreditors: The Commission on Accreditation of Rehabilitation Facilities (CARF), Council on Accreditation (COA) or The Joint Commission (formerly JCAHO)
- Use a trauma-informed treatment model
- Have registered or licensed nursing staff and other licensed clinical staff, available 24/7, on-site according to the treatment model
- Demonstrate family engagement and outreach, including siblings, in the child’s treatment
- Provide discharge planning and family-based aftercare supports for at least six months post-discharge
The accreditation mandate sets a high bar, but one that helps ensure the delivery of high-quality care. Organizations that earn accreditation have reached beyond the minimum licensing standards and made a long-term commitment to strong governance, program consistency, outcome measurement and continuous improvement throughout their agencies.
Accreditation requires organizations to undergo an objective review by an independent accrediting body and signifies that they are effectively managing their resources and enhancing the quality of life for the population served.
Many organizations underestimate the time required to prepare for and become accredited. In general, it takes 12 to 18 months to prepare for national accreditation, sometimes more, sometimes less, depending on the original state of readiness.
The time needed to complete the accreditation process includes, but is not limited to, the following:
- Selecting an accrediting body
- Securing budgetary allotment and board approval
- Preparing standards-compliant policies, procedures and protocols
- Implementing accreditation standards
- Making operational and service delivery improvements, as necessary
- Participating in a mock survey
Because Family First represents a looming, national deadline for accreditation, there will be many hundreds (if not thousands) of organizations trying to become accredited at the same time. And the accrediting bodies only have a finite amount of capacity to accommodate all of these applicants.
Therefore, every organization should begin the accreditation process as soon as possible to get ahead of the rush. Once the process begins, effective project management and support from leadership will help ensure that accreditation activities are not derailed by other priorities that may crop up.
For information on how to effectively and pro-actively prepare for CARF, COA or Joint Commission accreditation, please contact Accreditation Guru, Inc. at Info@AccreditationGuru.com or 212.209.0240.