The Final Deadline for Implementing FFPSA is One Year Away – Here’s What You Should Know

In 2018, the Family First Prevention Services Act (FFPSA) mandated that Qualified Residential Treatment Programs (QRTPs), in part, must be licensed by their state and achieve national accreditation to receive Title IV-E funds following the initial two weeks after a child enters their care.[1]  The time originally allocated to submit program plans was two years with the potential for taking a two year delay.

Although agencies and states have evolved in their understanding and communication of many aspects of the federal bill, presently only twelve states, plus the District of Columbia and two tribes have submitted Title IV-E Prevention Program plans, which indicates when the state intends to implement FFPSA. Additionally, we now find ourselves just one year out from the final implementation deadline of October 1, 2021.

From an agency accreditation perspective – this means that while there is still time to become accredited, it will need to be done with a consistent effort, focus on efficiency, and a continuous eye on timing. 

In general, it takes 12 to 18 months to prepare for national accreditation; depending on the original state of readiness and the accrediting body selected. If you have not yet discussed the subject within your organization, now is the time.  Below, we have compiled some facts and important steps you can and should be taking now if you wish to become a QRTP.

FACT:  TIMING IS EVERYTHING: This is a crucial piece to understand and communicate within the organization.  When an agency’s board and staff understand the time constraints that you are working within – the probability of quicker responses, approvals and/or comments will increase.

Important Steps

Select an Accrediting Body –The accrediting bodies approved under FFPSA are: CARF International (http://carf.org), Council on Accreditation (COA) (https://coanet.org/) , The Joint Commission (https://www.jointcommission.org/), or other accrediting bodies approved by the Department of Health and Human Services (HHS).[2]   We have a helpful chart that compares the three accrediting bodies.  Contact us for that and/or for input on which accrediting body would be best suited for your organizations’ needs.

Know Your Baseline – Benchmarking your organizational starting point against the expectations of accreditation will allow you to focus more time on the less developed aspects of your plan.   It will also help anyone who is working with you to start with this information and move you forward from there, rather than taking the time to fact find on your behalf.  One way to establish your readiness for accreditation is to take our Free Readiness Assessment.  

FACT: BUDGETING NOW WILL SAVE TIME LATER:  Plan now to secure budgetary allocation with the board’s approval for the entire amount ahead of time.  As the process can take a year or more to complete; accreditation could theoretically be spread over two budget cycles and you may be tempted to push off getting part of the total spending approved until the second budget cycle. However, this simple task can literally add weeks to the project – when you need to stop for approvals and get payments routed for signatures before proceeding to next steps.

Important Steps:

Include Benefits in the Proposal:   You are already aware of the importance of understanding all accreditation costs up front, but clearly identifying and including the benefits to the expenditure in your proposal when routing to key decision makers is also crucial.  To ensure you have a clear outline of benefits of accreditation, you can review our articles, blog posts and videos that can help clarify the points that make the most sense for your organization. Go here and type in “benefits” in the search area to pull up relevant info.

FACT: BOARD AND STAFF BUY-IN IS KEY:  Preparing staff and board members for the accreditation process is one of the most overlooked but (in our experience) one of THE most valuable investments you can make prior to starting the process.  Organizations often think that one person will lead the charge on finding a team and holding the team accountable to the tasks at hand.  But this is often done at the expense of day-to-day responsibilities.  By clarifying not only what the accreditation process entails but why it is happening – more people will have a sense of the timeliness involved and be motivated to help.

Important Steps:

Plan for Getting Buy-in as an Event.  Appointing one person, or team of individuals (perhaps an accreditation communications committee) to be the accreditation point of contact for agency staff and other stakeholders can assist in making the accreditation process an enjoyable one for all. Allowing a bit of latitude can be beneficial and a bit of fun, for example, kick-off events, holding an accreditation fair to exhibit new accreditation policies and procedures to one another, trivia contests, accreditation field days, team picnics, etc. There are people who enjoy accreditation, so find them and utilize them!

Consider a consultant.   Achieving accreditation is an involved process that will require your employees to spend less time on their day-to-day responsibilities. To ensure efficient time management, consultants go beyond providing training functions and serve as sounding boards to answer questions from staff so no one is spinning their wheels or getting lost down a rabbit hole trying to figure out what the accreditation standards mean.  Contact us to start a conversation on how we can help you get this done on time and budget.

With the FFPSA deadline looming, impacted organizations should begin the accreditation process now to get ahead of the influx of other providers seeking to become accredited and have enough time to thoroughly 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.

Accreditation Guru assists organizations in creating a customized accreditation timeline based on its strategic planning and provides support along the way to successfully meet each milestone.  A accreditation calendar provides a visual tool to keep leadership and staff focused for an efficient process.

[1] Public Law 115-123,section 50741 (page 190); available at: https://www.congress.gov/115/bills/hr1892/BILLS-115hr1892enr.pdf

[2] Two additional accrediting bodies have been approved for QRTPs since the passing of the law: Educational Assessment Guidelines Leading toward Excellence (EAGLE) (http://eagle1.org/) – a faith-based accrediting body – and Teaching-Family Association (https://www.teaching-family.org/)


For more information or questions about the contents of this article, please write or call Jennifer Flowers @ Jennifer@AccreditationGuru.com / 212.209.0240.   This post contains original content and was written for Accreditation Guru, Inc. Use of this copy is permitted with credit and reference within the same body of copy to Accreditation Guru, Inc.

Happy Birthday FFPSA! Now in Effect, New Law is Changing Child Welfare Services

Individuals, agencies and associations in the child welfare space have been preparing for the initial implementation date of the Family First Prevention Services Act (FFPSA) even before it was signed into law in February of last year.

This act, which aims to change the face of child welfare in the United States, required implementation by October 1, 2019, unless a particular state opted to delay enforcing its provisions for up to two years. At last count, only nine states, plus the District of Columbia, are planning for early (2019) implementation of FFPSA.

For more than a year, Jennifer Flowers, CEO of Accreditation Guru, has delivered numerous presentations around the country about FFPSA’s accreditation mandate for a new category of congregate care providers: Qualified Residential Treatment Providers (QRTPs).

In addition to solo speaking appearances, she has moderated numerous panels with top administrators from the three accrediting bodies approved under FFPSA (CARF International, Council on Accreditation and The Joint Commission) at a variety of major conferences. Specifically, Jennifer has spoken for the Association of Children’s Residential Centers, Family Focused Treatment Association, Annie E. Casey Foundation and the Children’s Defense Fund, among many others.

 

It’s fitting that on October 1, the birthday of FFPSA’s implementation, Jennifer moderated a panel at the Texas Child Care Administrators Conference, which included panelists representing the three approved accrediting bodies as well as Kristene Blackstone, Associate Commissioner for Child Protective Services in Texas – one of the largest CPS programs in the nation. Following Jennifer’s summary of FFPSA and what it means to become a QRTP, the panel launched into a lively discussion about accreditation and the rollout of FFPSA in the State of Texas.

For more information about FFPSA, visit AG’s webpage devoted to this topic. And, for inquiries about assistance with preparing for national accreditation or for information about Jennifer Flowers speaking at your event, please contact Rocio@AccreditationGuru.com.

EAGLE Recognized now as an Approved Accreditor for QRTPs Under the Family First Prevention Services Act

On May 15, it was announced that EAGLE Accreditation Program is recognized by the Department of Health and Human Services as an approved accreditor for Qualified Residential Treatment Programs (QRTPs) under the Family First Prevention Services Act (FFPSA). As we have discussed here, FFPSA, which passed in February 2018, allows federal funds to be spent on preventative services to help keep families together and also restricts funding on congregate care or group homes for children and youth who require removal from their families. In part, FFPSA mandates that all residential treatment providers convert to QRTPs, a new licensing category, in order to be eligible for reimbursement through Title IV-E foster care funds after the first two weeks of child placement.

One of the requirements to become a QRTP is to be accredited by CARF, COA, The Joint Commission and now, for the first time, EAGLE Accreditation.

EAGLE, which stands for Educational Assessment Guidelines Leading toward Excellence, is the only faith-based accrediting body in the country. It focuses on ministries serving older adults, children, youth and families, and those with developmental disabilities with emphasis on excellence, quality and how applicant organizations incorporate their Christian mission, religious heritage and values throughout the organization and its daily operations. EAGLE accreditation has provided an option for faith-based organizations since 1984.

The EAGLE Accreditation Program is operated by the United Methodist Association of Health and Welfare Ministries (UMA).

“We are proud of this recognition for EAGLE,” said Mary Kemper, president and CEO of UMA. “As an accreditor of faith-based organizations for more than 40 years, EAGLE has a solid history of promoting excellence with the added focus on organizations’ faith-based mission, vision and values.”

For questions about EAGLE or other accrediting bodies and for assistance preparing your organization to become a Qualified Residential Treatment Program, please contact Accreditation Guru at Info@AccreditationGuru.com.

For more information about FFPSA, visit our FFPSA Resource Page and blog.

For full press release click here.

Accreditation Guru’s Family First Prevention Services Act Resource Page is now live!

This informational package provides resources and tips related to FFPSA and the requirements regarding Qualified Residential Treatment Programs (QRTP), the new category of service provider delivering out-of-home care to kids in the child welfare system. Here you will find articles and fact-sheets, information on each of the three accrediting bodies approved under FFPSA (CARF, COA and The Joint Commission) and guidance about the timing required to achieve accreditation.

Please visit our new FFPSA Resource Page for more information.

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 Qualified Residential Treatment Programs Under the Family First Prevention Services Act: The Time to Start the Process is 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.

Jennifer Flowers of Accreditation Guru Presents Seminar to National Audience at the Children’s Defense Fund in Washington, D. C

Washington, D.C. (May 1, 2018) — Jennifer Flowers, founder and CEO of Accreditation Guru, delivered a well-attended, well-received seminar to members of the National Child Welfare and Mental Health Coalition at the national headquarters of the Children’s Defense Fund in Washington, D. C. Several coalition members participated over conference call.

Entitled “Family First Prevention Services Act – Accreditation 101: Understanding the Accreditation Process for Qualified Residential Treatment Programs,” the presentation covered the new law’s impact on congregate care programs throughout the United States and outlined the basic steps and considerations these organizations must undertake to comply with the statute.

“Jennifer’s reassuring, helpful presentation emphasized the positive impact of accreditation on the quality of care for children and walked through the multiple steps involved, reminding us all of the time it takes for service providers to work their way toward accreditation,” said Stefanie Sprow, deputy director of child welfare and mental health at the Children’s Defense Fund, which chairs the Child Welfare and Mental Health Coalition and its series on implementing the Family First Prevention Services Act. “As one of the nation’s foremost experts in this field, Jennifer’s perspective is invaluable.”
The new law, passed February 2018, requires all qualified residential treatment programs (QRTPs) to become accredited by October 1, 2019 if they want to receive Title IV-E federal funding. But because the accreditation process can sometimes take up to 18 months to complete and a large number of organizations have yet to begin the process, accrediting agencies will be stretched to meet the additional demand. Time is getting short, said Flowers.

Operating under the Children’s Defense Fund umbrella, the coalition consists of approximately 250 people, spanning national, state and local organizations, the bulk of which provide child welfare services.

The interesting and informative presentation outlined the many benefits of national accreditation and covered the basic steps along the accreditation journey. Providers must choose among three accrediting bodies approved by the Department of Health and Human Services, document their adherence to their rigorous standards, submit to a review and site survey by the chosen accrediting agency and maintain the standards for either a three or four year period.

She also offered some tips for helping to smooth the process. The long, involved process can be demanding for service providers, but, said Flowers, they can either “plan or panic.”

Addressing the group by phone from Memphis, Hughes Johnson, managing director of compliance and performance improvement at Youth Villages, which operates in 14 states across the country, shared his organization’s experiences with accreditation. He called Flowers’s presentation spot-on.

“The accreditation and re-accreditation process helped us raise the bar for our staff and the population that we serve,” he said. “It is a tough process with a large number of standards, but it helped us develop a defined policy that holds us accountable.”

Flowers, a nationally renowned expert on accreditation and best practices for human service providers, advises organizations undergoing accreditation.

“In general, service providers are laser-focused on delivering quality care and they often fail to realize that accreditation is a complicated, involved process,” said Flowers. “This served as a wonderful opportunity to help members of the coalition provide valuable information to their constituents and help introduce them to the process.”

About Accreditation Guru, Inc.
Accreditation Guru has helped guide private and public health and human service organizations through the national accreditation process by creating an efficient, systematic approach that has resulted in a 100 percent success rate. Their expertise also includes implementing performance measurement and quality improvement programs, developing long-term strategic plans and increasing the effectiveness of boards of directors. For information about their services and how they can help your organization Prepare for Greatness™, please visit https://accreditationguru.com.

Left to right:
Stefanie Sprow, Deputy Director of Child Welfare and Mental Health at the Children’s Defense Fund
Jennifer Flowers, Founder and CEO of Accreditation Guru
MaryLee Allen, Director of Policy, Children’s Defense Fund