When Entitlements Collide: Title IV-E and Medicaid in a Family First World

There are now less than two months until the major reforms of the Family First Prevention Services Act take effect. The central objectives are to realign the Title IV-E child welfare entitlement to include federal funds to help prevent the need for foster care in some cases, and limit federal funds for placements into group homes and other “congregate care” settings.

In the past year since it became law, there has been a steady trickle of guidance out of the U.S. Children’s Bureau on implementing the major provisions of it. New definitions in the law have been clarified, and a clearinghouse has started to clear evidence-based services for funding.

But one piece of the puzzle that remains a point of great confusion and uncertainty is how IV-E and a much larger entitlement, Medicaid, coexist in the new world order envisioned by Family First. At a regional meeting on Family First held in April, this emerged as the biggest issue on the minds of state child welfare officials.

“Where there’s some real opportunities for ongoing conversation is … where might Medicaid pick up and IV-E not pick up,” said Page Walley, public policy officer for St. Francis Ministries, which helped organize that regional meeting. “There’s some real questions about the process there,” as well as a need for “engagement with Medicaid offices.”

Next Monday, The Chronicle of Social Changehopes to provide some clarity on the confusion, if you will. Heather Baker of Public Consulting Group and Pat Johnston of the National Association for Children’s Behavioral Health will join us for a webinar to discuss how Family First has created some blurred lines around these critical entitlements.

There are two general areas where Medicaid and IV-E bump up against each other in the Family First era.

Prevention Services: The guidance thus far suggests that if Medicaid can pay for an evidence-based service allowed under Family First, Medicaid must be used to pay for it. This makes IV-E the “payer of last resort.”

Since Medicaid plans vary from state to state, and are not always run out of the same agencies that oversee child welfare, this is a standard that could create a lot of complexity in figuring what states can and will invest in to help keep families together.

Congregate Care: The Family First act limits federal funding of most placements in group care to two weeks, but the biggest exception to that rule is a newly created category of providers called Qualified Residential Treatment Programs (QRTP). This marks the first time that the federal government has categorized a specific type of health-related congregate care setting in the foster care continuum.

The rules around using Medicaid for serving kids in congregate care are quite blurry now. And there is concern about the inclusion of a new health setting, that would likely notqualify for Medicaid funding.

Confused? We have great guests ready on the webinar to help attendees through the complicated connection between Medicaid and child welfare under the new world order of Family First.

“When Entitlements Collide: How Medicaid Affects the Family First Act” is scheduled for 1 p.m. EST on Monday, Aug. 19! Learn more about our webinars here.

And if you missed the Aug. 19th session, you can view the recording and slides here.

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John Kelly
About John Kelly 1108 Articles
John Kelly is editor-in-chief of The Chronicle of Social Change.