Next week, the Alliance, along with other policy partners, is organizing a day of action to help ensure the Child Abuse Prevention and Treatment Act (CAPTA) is fairly funded. Now is a critical time to weigh in. The House of Representatives proposed increased funding for CAPTA by $35 million and the Senate proposed level funding. As negotiations on the budget continue, we are advocating for Congress to keep the House numbers in the final budget. Time is running out, and we need to call on Congress now. Join our social media day of action Tuesday, Oct. 15 by telling your members of Congress about the importance of funding CAPTA.

To make things easier, use our Twitter tool, which will automatically craft a tweet from you and tag your representatives. If you want to create your own tweet, make sure to include your representative's Twitter username and these hashtags when posting/tweeting: #CAPTA #PreventChildAbuse #StrengthenFamilies #HealthyChildhoods Access sample tweets and Facebook posts.

The Children’s Defense Fund, in concert with several partner organizations, has released an in-depth guide to the Family First Prevention Services Act (FFPSA). The goal of the guide is to aid government agencies and service providers in navigating the complicated provisions of FFPSA. The guide covers the intent of the legislation and answers frequently asked questions in a clear, illuminating manner. It is helpful for all types of stakeholders that are grappling with the major changes that will be occurring in child welfare over the next few years. Download the guide for free.

Family First & Medicaid: The IMD Issue Posing a Threat to QRTPs

Recently, Kentucky reached out to its regional Medicaid office for a clarification on whether Qualified Residential Treatment Programs (QRTP) are considered Institutions for Mental Diseases (IMDs), meaning they would not qualify for Medicaid reimbursement. In response, it was told that they could not bill Medicaid for any services within its QRTPs that exceed 16 beds. This confirms concerns that QRTPs, which are meant to provide treatment services for foster youth threaten the ability of providers to bill Medicaid for treatment. As a result of the Kentucky decision, the Centers for Medicare and Medicaid Services (CMS) have confirmed that they are not planning on making any exceptions for the new QRTP designation. Group settings with more than 16 beds would trigger the IMD rule, thus making any health services administered there unbillable to Medicaid. This has the potential to threaten the infrastructure of QRTPs and create a debate about how congregate care health services are paid for. 

Typically, any facility with more than 16 beds and with more than half of its residents holding a diagnosis in the DSM would be considered an IMD. This would mean you cannot bill Medicaid for any health services. Title IV-E dollars do not cover the actual mental health treatment in a QRTP. It essentially just covers room and board.

The Centers for Medicare and Medicaid Services recently released a technical assistance memorandum suggesting that it does not have any intention of making an exception to the IMD rule for QRTPs through guidance and rulemaking. It states that QRTPs can avoid falling into the IMD rule if they are less than 16 beds or if they attain licensure as a Psychiatric Residential Treatment Facility (PRTF). 

Advocates are reviewing options and considering various “fixes” to address this issue. One option would be to add QRTPs to an allowable list of exceptions in the Psych-Under 21 Benefit. Another possibility is to develop new legislation that would exempt QRTPs of any bed size from the IMD rule. Some advocates are even pushing for an entire elimination of the IMD exclusion for Medicaid eligible people younger than 21.

Source: The Chronicle of Social Change

New Refugee Resettlement Rule

On Sept. 26, the Trump administration issued an executive order that requires the federal government to consult with state and local governments before resettling refugees. States and localities did not have this level of power before. The administration argues that state and local governments know best whether they have the resources to efficiently and humanely resettle vulnerable populations. Seeking local authorization could potentially curtail refugee resettlement efforts because some localities may pass up the opportunity to accept refugees. 

The administration also released new figures on the number of refugees to be admitted next year. For fiscal year 2020, 18,000 refugees will be accepted, a substantial drop from fiscal year 2019. This figure includes 4,000 Iraqis; 5,000 fleeing religious persecution; and 1,500 individuals from Northern Triangle countries. An additional 350,000 asylum seekers will be admitted for fiscal year 2020, out of a backlog of approximately 1 million individuals. 

New SNAP Eligibility Rule

On Oct. 3, the U.S. Department of Agriculture (USDA) released a proposed rule that, some experts say, will cut $4.5 billion in food stamp benefits over the next five years. The USDA is arguing that changes need to be made to the way household utility costs are factored into the benefit formula. Currently, households can deduct a portion of their shelter and utility costs from their income, allowing them to qualify for larger benefits. Rather than ask each household to provide utility expenses every month, states use average utility costs, called Standard Utility Allowances (SUA), that are unique to the state or local area. The Trump administration’s rule would scrap state and local SUA’s for a national SUA. This change, by some estimates, could reduce benefits by $30 per month for 20% of households that receive food stamps. This is the third time in the past year that the Administration has proposed a rule that would reduce food stamp benefits for families in need.

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