By Penny Gross
Proposed CSA Policy Would Have Significant Impact to Localities
As you may know, the State Executive Council (SEC) will vote later this month on a proposed policy regarding youth referred to residential treatments facilities (RTFs) outside of the Comprehensive Services Act (CSA) process. I am very concerned about the impacts this proposal will have if it is adopted.
First, I am concerned about the fiscal impact of the proposed policy to our localities. Currently, the local Family Assessment and Planning Team (FAPT) assesses, approves and funds services that are appropriate for a particular child. Under the proposed policy, the FAPT would not be brought into the process until after a child has entered an RTF and would not have the opportunity to explore less expensive community-based options. Further, a local Medicaid match is required for every placement where CSA pays for educational costs.
Second, the proposed policy also generates unreasonable time frames for FAPT review. The proposal requires that if a child is admitted to a residential treatment facility prior to review, the FAPT shall assess the youth within 14 days of the admission to the RTF and shall develop an Individualized Family Services Plan (IFSP) for services appropriate to meet the needs of the youth. Moreover, the proposal does not account for localities with large FAPT caseloads, localities with part-time coordinators, and those with regional FAPTS.
I believe it is critical for the SEC to delay any action on the proposed policy until all public comments have been received and thoroughly discussed by the appropriate stakeholders. Please find VACo’s letter to the SEC addressing these concerns here.