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.

 

Addiction Treatment Centers Need Certification to Advertise on Facebook

Last year, Google barred advertisements from appearing in search results for addiction treatment centers in the United States. Starting last month, however, the company allowed centers with LegitScript Addiction Treatment Certification to run ads on its platform.

Now, Facebook recently announced that it will also require that addiction treatment centers achieve certification before they are approved to advertise on its properties, including Instagram and Messenger. LegitScript, a verification and monitoring service for online pharmacies, charges $995 for initial certification and $1,995 for annual vetting.

Google and Facebook’s advertising restrictions stemmed from complaints about addiction centers that targeted people suffering from addiction, offering sub-par clinical services to the highest bidder or making out-of-state recommendations solely to collect a referral fee. Other disreputable addiction treatment centers inflate staff qualifications and engage in improper billing.

Still, it is important to remember that certification represents a lower standard than accreditation. There is no need to rely on random internet searches to find reputable addiction treatment providers: just determine if a given organization is nationally accredited by an independent accrediting agency.

To earn national accreditation, an external panel of experts conducts thorough on-site scrutiny of addiction and human services organizations to ensure that they adhere to the rigorous guidelines and criteria set by the nationally recognized accrediting bodies. The initial process takes up to a year of preparation and organizations must reapply for accreditation every three or four years to maintain the designation.

National accreditation provides independent third-party validation of an organization’s quality of care. Addiction treatment centers and other human service organizations usually tout this status on their websites. Reputable treatment providers can also be found directly on the accrediting bodies’ websites, including The Joint Commission (formerly JCAHO), the Commission on Accreditation of Rehabilitation Facilities (CARF) and the Council on Accreditation (COA).

LegitScript’s certification applies to “any website, application, or merchant that provides information about in-person drug or alcohol addiction treatment, or facilitates in-person or online drug or alcohol treatment, other than at a private residence or non-clinical setting.” Recovery residences that “do not provide clinical services or addiction treatment, provide or purport to provide a cooperative living environment in a non-commercial location (a private residence or similar setting), and are not part of a larger treatment program offered by an addiction treatment provider, are not eligible for certification.”

Read more about the crackdown on addiction treatment advertising online here

Celebrating Foster Parents During National Foster Care Month

As I reflect on over 20 years serving as a foster care worker, what comes to mind first are the foster parents. I’ve recruited, trained, licensed, counseled, laughed and cried with foster parents and enjoyed most every moment.

Whether you are reading this as a person interested in fostering, an agency with a foster care program, a professional in the field, a child advocate, or just found this blog searching the web, I assure you my comments come from experience not only as a foster care worker but also as a former foster parent.

Foster parents are one of the most undervalued commodities in our country and we need a continuous growing pool of them.  With over 437,000 children currently in foster care across the U.S., the need for foster parents is tremendous nationally. Foster parents are our safety net for abused and neglected children, and the system is challenged with recruiting, supporting and retaining them.

The experience of a foster parent can’t be measured by conventional methods. The emphasis our society puts on academic degrees and professional success leaves out the intangibles. A foster parent’s value is in their devotion, their emotional and physical commitment to the well-being of a vulnerable child.

Who makes a great foster parent? A kind and compassionate person who has the desire to parent, teach, and love someone else’s children. We all may know people who could fulfill those requirements, but then there’s the hard fact that these kids are part of a system and a challenging one at that. The bureaucracy that faces foster parents often discounts their input even if it’s clear that they are the ones who know best what will help the children in their care.

If you are interested in possibly becoming a foster parent, here are some important tips to keep in mind:

  • Check to see that the foster family agency holds a national accreditation by either CARF, Council on Accreditation (COA) or the Joint Commission – this tells you that the organization values best practice standards that are well above state minimum rules and regulations. I have worked for several agencies in my career, some nationally accredited and some not. The difference was notable in areas of support to foster parents, staff, and overall agency professionalism.
  • Accredited agencies provide outstanding support to foster parents and additional child-specific training.
  • Ask to speak with other foster parents, attend an orientation, and meet with the program director.
  • Ask to see the agency’s program goals and outcomes for foster care.
  • See how foster parents are included in organizational quality improvement process.
  • If you are looking at a nonprofit agency see what the composition of the board of directors is and if they are involved in activities to support foster parents.
  • Review a non-profit agency’s IRS form 990, which are available online at https://www.guidestar.org.
  • With a for-profit agency, you may want to research the leadership team.

May Is National Foster Care Month. With that, we should all take the time to recognize that we each can play a part in enhancing the lives of children and youth in foster care. Hats off to all of the foster parents out there!

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.