By Jennifer Flowers, Founder & CEO, Accreditation Guru, Inc.
When it passed the Family First Prevention Services Act (FFPSA) last February, Congress aimed to change the face of child welfare by implementing a funding shift that restricts the use of Title IV-E financing for out-of-home placements, excluding foster homes.
The goal is to increase assurances that children will be kept in family-like settings whenever possible. One chapter 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!
Out-of-home service providers must become QRTPs by October 1, 2019. States have the option to extend this deadline for up to two years, but this would also delay funding for prevention services and kinship navigator programs for the same length of time. For now, 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 HHS-approved accreditors: 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
In addition, due to the mandate, there may be 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.
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 ensure that accreditation activities are not derailed by other priorities that may crop up.
Under the Family First act, QRTPs have a limited amount of time in which to become accredited and are encouraged to begin the process as soon as possible. Remember, Oct. 1, 2019 is less than 17 months away!
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 or visit our website at https://accreditationguru.com/.
The text of the bill can be read on approximately page 424 of the CR here.
The Alliance has written a summary of the bill.
 Federal financing will provide reimbursements after the first two weeks a child has been in a congregate setting for the following specified categories only:
- Qualified Residential Treatment Programs
- Placement settings that specialize in supporting pregnant or parenting teens
- Supervised independent living settings for an 18-year-old
- Programs that provide high quality residential care and support services to children and youth who are at-risk of sex trafficking
 Or other accrediting bodies approved by the Secretary.
 Nurses and behavioral health staff need not be employees of the QRTP.
 Both CARF and COA require implementation of accreditation standards for a minimum of six months before any onsite survey takes place.