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The 2016-17 Budget: Analysis of the Human Services Budget

Legislative Analyst's Office · lao-3351 · Report · 2016-02-11

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The 2016-17 Budget: Analysis of the Human Services Budget MAC TAYLOR • L E G I S L A T I V E A N A L Y S T • FEBRUARY 2016 2016-17 BUDGET 2 Legislative Analyst’s Office www.lao.ca.gov 2016-17 BUDGET EXECUTIVE SUMMARY Overview of the Human Services Budget. The Governor’s budget proposes $12.2 billion from the General Fund for human services programs—a 3.9 percent increase over 2015-16 estimated expenditures. The year-over-year changes mainly reflect the combination of (1) continued implementation of previously enacted policy changes; (2) changes in caseload, utilization of services, and cost per unit of service; and (3) new policy proposals in the Department of Developmental Services (DDS) and, to a lesser degree, the Supplemental Security Income/State Supplementary Payment (SSI/SSP) program. (We will be providing more information of the Governor’s major proposals in DDS in our upcoming publication, The 2016-17 Budget: Analysis of the Developmental Services Budget.) Legislature Will Want to Evaluate Administration’s SSI/SSP Proposal in Light of Its Own Goals. The Governor’s 2016-17 budget proposal includes six months of funding to provide a one-time cost-of-living adjustment (COLA) to the state-funded SSP portion of the SSI/SSP grant. If the Legislature has an interest in increasing SSI/SSP grants, we find that the Governor’s proposal to provide a one-time COLA to be one way to do so. However, we think that the Legislature will first want to set its own goals for where it would like SSI/SSP grants to be, and over what time period it would expect to take to get there. Once these goals are established, the Legislature would be in a better position to consider the specific grant proposal made by the Governor. By establishing its goals for the program, the Legislature can ensure that any funding provided for SSI/SSP grant increases is used in a way that furthers those goals. Governor’s Proposals for In-Home Supportive Services (IHSS) and California Work Opportunity and Responsibility to Kids (CalWORKs) Appear Reasonable. We have reviewed the administration’s 2016-17 budget proposals for IHSS and CalWORKs. While we raise some areas of uncertainty—mainly related to caseload estimates in CalWORKs and the recent implementation of federal labor regulations in IHSS—overall we find the administration’s proposals to be reasonable at this time. We will continue to monitor these areas of uncertainty and update the Legislature if we think any updates to the caseload and budgeted funding levels should be made. Governor’s Continuum of Care Reform (CCR) Proposal Is Logical Next Step, but Some Uncertainty Remains. The Governor’s budget proposes funding in 2016-17 to continue to implement CCR in the state’s foster care system. At a high level, CCR aims to reduce reliance on long-term group home placements and increase the utilization and capacity of home-based family placements for children in the foster care system. We provide background on CCR, describe the Governor’s funding proposal, and highlight key areas of remaining uncertainty surrounding CCR implementation. While we think that the Governor’s budget is a logical next step in the implementation of CCR, we suggest some key issues and questions for legislative consideration with the goal of gaining some clarity around these remaining areas of uncertainty. www.lao.ca.gov Legislative Analyst’s Office 3 2016-17 BUDGET 4 Legislative Analyst’s Office www.lao.ca.gov 2016-17 BUDGET OVERVIEW Background on Human Services child welfare and adult protective services General Fund costs. California’s major human services programs Legislation enacted in 2013 shifted additional provide a variety of benefits to its citizens. These General Fund costs in the CalWORKs program include income maintenance for the aged, blind, or to local realignment revenues that previously have disabled; cash assistance and employment services been used to provide health services to indigent for low-income families with children; protecting individuals. These realignment revenues have been children from abuse and neglect; providing home freed up given that many indigent individuals care workers who assist the aged and disabled in are newly eligible for coverage in the state- remaining in their own homes; collection of child funded Medi-Cal program. The 2013 legislation support from noncustodial parents; and subsidized additionally provided that the costs of specified child care for low-income families. ongoing increases to the CalWORKs assistance Human services are administered at the state payments will be shifted to revenues from the level by the Department of Social Services (DSS), growth of existing local realignment revenues that Department of Developmental Services (DDS), otherwise would have supported other human Department of Child Support Services, and other services programs. We discuss the statutorily California Health and Human Services Agency driven CalWORKs grant increases in greater detail departments. The actual delivery of many services later in the “CalWORKs” section in this report. takes place at the local level and is typically carried out by 58 separate county welfare departments. Expenditure Proposal by Major Programs A major exception is the Supplemental Security Overview of the Human Services Budget Income/State Supplemental Payment (SSI/SSP), Proposal. The Governor’s budget proposes which is administered mainly by the U.S. Social expenditures of $12.2 billion from the General Security Administration. In the case of DDS, Fund for human services programs in 2016-17. As community-based services (the type of services shown in Figure 1 (see next page), this reflects a net received by the vast majority of DDS consumers) increase of $453 million—or 3.9 percent—above are coordinated through 21 nonprofit organizations estimated General Fund expenditures in 2015-16. known as regional centers. Summary of the Major Budget Proposals and Recent Major Changes in Funding for Human Changes. As shown in Figure 1, the budget reflects Services. As a result of realignment-related generally stable General Fund expenditures across legislation in 2011 and 2013, the budget reflects a majority of the human services programs, with shifts to counties of a significant amount of relatively higher growth in DDS. Major new policy- General Fund costs in human services programs. driven spending proposals are concentrated in DDS Specifically, as a result of 2011 legislation, the and, to a lesser extent, SSI/SSP. While in some cases budget (beginning in 2011-12) reflects shifts to the year-over-year funding growth appears modest local realignment revenues of about $1.1 billion or flat, this is actually masking both cost increases of General Fund costs in the California Work and decreases within the program. We highlight Opportunity and Responsibility to Kids the major budget changes below. (CalWORKs) program and about $1.6 billion in www.lao.ca.gov Legislative Analyst’s Office 5 2016-17 BUDGET DDS. The 7.5 percent growth ($265 million) is almost completely offset by proposed increased in DDS General Fund expenditures is driven in funding for the continuation of the implementation part by several new spending proposals primarily of the Continuum of Care Reform (CCR). At a high aimed at supporting community services as level, the funding provides for additional resources well as their development in preparation of the to improve the state’s child welfare system by continued closure of developmental centers. (We performing comprehensive assessments of children will provide more information on the Governor’s to ensure that their initial placement is the most major proposals in DDS in our upcoming DDS appropriate setting, increasing the use of home-based publication, The 2016-17 Budget: Analysis of the family care, and reducing the use of group homes. Developmental Services Budget.) Some funding was provided for CCR in 2015-16, CalWORKs. The 6 percent growth ($43 million) and the Governor’s budget continues this, and some in General Fund expenditures in CalWORKs additional funding, in support of this effort. largely reflects funding shifts and masks a decline In-Home Supportive Services (IHSS). It is (3 percent) in total funding for the program from important to note that the modest (1.1 percent) all sources. The decline in total funding is primarily year-over-year net growth in the IHSS General the result of lower estimated caseloads. Fund expenditures masks a number of both cost DSS Nonrealigned Children’s Programs. increases and savings. On the cost front, the The slight decrease in General Fund support for budget reflects increased costs for a full year of the nonrealigned children’s programs under the implementation of compliance with new federal DSS budget is primarily the result of the cost of a labor regulations, caseload growth, and higher costs one-time set-aside to pay for a $50 million federal per service-hour as a result of wage increases. On penalty in 2015-16. Although this $50 million is the savings front, the Governor’s January budget not included in 2016-17, the year-over-year savings proposes to continue to restore IHSS service hours Figure 1 Major Human Services Programs and Departments—Budget Summary General Fund (Dollars in Millions) Change From 2015-16 to 2016-17 2015-16 2016-17 Estimated Proposed Amount Percent SSI/SSP $2,795.9 $2,872.8 $76.8 2.8% Department of Developmental Services 3,508.8 3,773.5 264.8 7.5 CalWORKs 697.7 740.5 42.8 6.1 In-Home Supportive Services 2,934.4 2,966.0 31.6 1.1 County Administration and Automation 824.3 855.1 30.8 3.7 Nonrealigned Children’s Programsa,b 259.5 255.6 -3.9 -1.5 Department of Child Support Services 314.3 314.2 -0.1 — Department of Rehabilitation 59.8 59.9 0.1 0.2 Department of Aging 33.4 33.8 0.3 1.0 All other human services (including state support) 334.7 345.0 10.3 3.1 Totals $11,762.9 $12,216.3 $453.4 3.9% a This includes, among other programs, the Kinship Guardianship Assistance Payment Program, Approved Relative Caregiver Program, and funding for the Continuum of Care Reform efforts. b The 2015-16 General Fund includes a $50 million set-aside for a potential federal penalty. This penalty is currently being appealed. If the state does not ultimately have to pay the penalty, or pay a lesser amount, General Fund costs in this area would be less. 6 Legislative Analyst’s Office www.lao.ca.gov 2016-17 BUDGET that were eliminated as a result of a previously SSI/SSP. Finally, although the year-over-year enacted 7 percent reduction in service hours, but growth in SSI/SSP would not be considered do so through a restructured tax on managed significant (2.7 percent), we note that unlike in care organizations (MCOs) rather than from the recent years, it includes funding increases for General Fund as was done in 2015-16. We note that more than just growth in the caseload. The budget on February 8, 2016, the administration released includes about $40 million to fund a one-time an updated MCO tax proposal. The administration cost-of-living adjustment (COLA) (estimated to be has indicated that funding to continue the IHSS 2.96 percent) to the state-funded, SSP portion of the service-hour restoration could come from either grant. MCO tax revenues or the General Fund. SSI/SSP The SSI/SSP program provides cash grants to statutorily required to provide an annual COLA low-income aged, blind, and disabled individuals. each January. This COLA increases the SSI portion The state’s General Fund provides the SSP portion of grant by the Consumer Price Index for Urban of the grant while federal funds pay for the SSI Wage Earners and Clerical Workers (CPI-W). portion of the grant. For 2016-17, the budget In years that the CPI-W is zero or negative (as proposes nearly $3 billion from the General Fund was the case in 2010, 2011, and 2016), the federal for the state’s share of SSI/SSP—an increase of government does not increase SSI grants, but $77 million (2.8 percent) over estimated 2015-16 instead holds them flat. The federal government expenditures. This increase would bring total gives the state full discretion over whether and how program funding to $10.3 billion ($2.9 billion from to provide increases to the SSP portion of the grant. the General Fund and $7.4 billion federal funds) Until 2011, the state also had a statutory COLA. in 2016-17. The primary drivers of this increase Although this statutory COLA existed, there were are modest caseload growth (less than 1 percent) many years that, due to budget constraints, the and the Governor’s proposal to provide a one-time COLA was not provided. The last state-funded COLA to the SSP portion of the grant. COLA was provided in April 2005. Caseload Growing Modestly. The SSI/SSP During Constrained Budget Environment, SSP caseload has continued to grow at a rate of less Grants for Individuals and Couples Reduced to than 1 percent each year since 2011-12. The budget Federally Required Minimum. The state is required estimates that about 1.3 million individuals and to maintain SSP grant levels at or above the levels couples will receive SSI/SSP grants in 2016-17, an in place in March 1983 in order to receive federal increase of 0.8 percent over 2015-16. Medicaid funding. As a result of difficult budget times during the most recent recession, the state Background on SSI/SSP Grants decreased SSP grants for individuals and couples to Both the State and Federal Government these minimum levels. As shown in Figure 2 (see Contribute to SSI/SSP Grants. Grant levels next page), for couples, the state reduced the SSP for SSI/SSP are determined by both the federal grant to the federally required minimum ($396 per government and the state. The federal government, month) in 2009-10. For individuals, SSP grants which funds the SSI portion of the grant, is www.lao.ca.gov Legislative Analyst’s Office 7 2016-17 BUDGET were first reduced by 2.9 percent to $171 per month required minimum levels, the state could no longer in 2009-10, and then subsequently to the federally do this. Despite the gradual increases in the grants required minimum of $156 per month in 2011-12. shown in the figure, current maximum SSI/SSP Because no state COLA has been provided since grant levels remain below the 2008-09 levels. these reductions, SSP grants for individuals and Governor’s Proposed One-Time COLA couples have remained at these minimum levels. Grants Have Been Gradually Increasing Budget Proposes One-Time COLA to SSP Due to Federal COLAs, but Remain Below Portion of Grant. The budget includes six months Pre-Recession Levels. As shown in Figure 2, the of funding ($41 million) from the General Fund to total SSI/SSP monthly grant amount for individuals increase SSP grants by the California Necessities and couples has been increasing since 2010-11— Index (CNI) beginning January 1, 2017. The solely due to the provision and pass-through of Governor’s budget estimates that the CNI will be federal COLAs. We note that during some difficult 2.96 percent. The annualized cost of this COLA budget times prior to 2010-11, the state negated is estimated to be approximately $80 million to the impact of COLAs by reducing the SSP portion $90 million from the General Fund. In addition, of the grant by the amount of the federal increase, the budget estimates that the federal government thereby holding total SSI/SSP grant levels flat. will provide a 1.7 percent COLA to the SSI portion After the state reduced SSP grants to the federally of the grant, also beginning January 1, 2017. Based Figure 2 Maximum SSI/SSP Grants for Individuals and Couplesa Compared to Federal Poverty Levelb Individuals Couples $1,700 1,600 SSP 1,500 SSI 1,400 Federal Poverty Levelb 1,300 1,200 1,100 1,000 900 800 700 600 500 400 300 200 100 08-09 09-10 10-11 11-12 12-13 13-14 14-15 15-16 08-09 09-10 10-11 11-12 12-13 13-14 14-15 15-16 a The maximum monthly grants displayed refer to those for aged and disabled individuals and couples living in their own households, effective as of January 1 of respective budget year. b Federal Poverty Level as established by U.S. Department of Health and Human Services, effective as of January 1 of respective budget year. 8 Legislative Analyst’s Office www.lao.ca.gov 2016-17 BUDGET upon the Governor’s estimate of the CNI and CPI, Grant Increases Should Reflect the the administration estimates that total monthly Legislature’s Goals for SSI/SSP Grant Levels maximum grants for individuals will increase by Setting Goals for SSI/SSP Grant Levels. The $17.09 and grants for couples will increase by $30.43. Governor’s proposal is one way to increase the With Revised CNI and CPI, Grant Increases SSI/SSP grant. It raises grant levels to all recipients Less Than Estimated by Governor. The CNI is and would essentially maintain grants at roughly an estimate of how the cost of living in California the same level relative to the federal poverty has changed from year to year. The Governor’s guideline as they are today. We think, however, that budget estimates that the CNI will be 2.96 percent, the Legislature will want to first set its own goals using partial data. Our review of the actual for where it would like SSI/SSP grant levels to be, data—published after the release of the Governor’s and over what time period it would expect to take budget—indicates that the January 2017 CNI is to get there. Once these goals were established, 2.76 percent (we expect this to be the final CNI). the Legislature would also be better positioned to Using the updated CNI, we estimate the proposed consider the specific grant increase proposal made January 1, 2017 SSP COLA would cost the by the Governor. Below, we provide examples of General Fund $38 million in 2016-17, a decrease of ways the Legislature may approach increases to the $3 million below the Governor’s January estimate. SSP grant—depending on its specific goals. The Governor’s budget estimates that the CPI-W Target Available Resources to Most Effectively that the federal government will use to adjust the Achieve Legislature’s Goals. As we described SSI portion of the grant will be 1.7 percent, but above, the Governor’s budget provides the same our estimate of the CPI-W is slightly lower, at 1.39 percent. (The actual Figure 3 CPI-W will not be known SSI/SSP Monthly Maximum Grant Levelsa until the fall.) As a result of Governor’s Proposal these downward estimates Governor’s 2016-17 Budget Proposal of the CNI and CPI-W, we LAO Estimates estimate that monthly SSI/ Governor’s Change From SSP grants would increase 2015-16 Estimatesb Amountc 2015-16d by $14.51 for individuals Maximum Grant—Individuals and $26.23 for couples SSI $733.00 $745.46 $743.19 $10.19 under the Governor’s SSP 156.40 161.03 160.72 4.32 proposal. Figure 3 shows Totals $889.40 $906.49 $903.91 $14.51 Percent of Federal Poverty Leveld 90% 92% 91% current maximum grant Maximum Grant—Couples levels for individuals SSI $1,100.00 $1,118.70 $1,115.29 $15.29 and couples compared SSP 396.20 407.93 407.14 10.94 to the Governor’s budget Totals $1,496.20 $1,526.63 $1,522.43 $26.23 Percent of Federal Poverty Leveld 112% 114% 114% proposal (as estimated by a The maximum monthly grants displayed refer to those for aged and disabled individuals and couples living in their own both the administration households, effective as of January 1 of the respective budget year. b Reflects Governor’s budget estimate of the (1) January 2017 federal cost-of-living adjustment (COLA) for the SSI portion of the and our office). grant, and (2) the Governor’s one-time January 2017 state-funded COLA for the SSP portion of the grant. c Reflects LAO estimate of the (1) January 2017 federal COLA for the SSI portion of the grant, and (2) the Governor’s one-time January 2017 state-funded COLA for the SSP portion of the grant. d Compares grant level to federal poverty guideline from the U.S. Department of Health and Human Services for 2016. www.lao.ca.gov Legislative Analyst’s Office 9 2016-17 BUDGET percentage grant increase for all recipients through In past years when state COLAs were provided, a one-time COLA. However, the Legislature may the state used a different methodology—a statutory have other goals for grant increases that could formula to adjust the total SSI/SSP grant by suggest targeting the increases among recipients. the CNI. It worked by applying the CNI to the As an example, if the Legislature established a combined SSI/SSP grant. First, the federal COLA goal to ultimately bring the maximum SSI/SSP was applied to the SSI portion of the grant, and grant for all recipients to 100 percent of the federal then the cost to increase the total, combined grant poverty level, it may not make sense to provide the by the CNI (after accounting for the federal COLA) same grant increase to all SSI/SSP individuals and was covered with state funding. This type of COLA couples (as proposed by the Governor), but instead effectively raises the total SSI/SSP grant by the CNI focus the available funding on individuals. This and may be referred to as a “whole-grant” COLA. is because grants for individuals are currently at This approach takes the view that the overall grant about 90 percent of the federal poverty guideline level is what should be maintained (rather than just while grants for couples are at about 112 percent. the SSP portion directly controlled by the state). Alternatively, the Legislature could set its goals For this option, the state cost is determined, in relative to another measure of poverty (such as the part, by the difference between the CPI and CNI. Supplemental Poverty Measure, which accounts for The higher (lower) the CNI is relative to the CPI, cost-of-living differentials). The cost to the General the greater (less) the state cost in applying this Fund for these types of targeted grant increases COLA methodology. We estimate that the cost of would vary by the grant level chosen, the size of providing this type of COLA in 2016-17 would be the population targeted, and the time period over about $115 million for six months of an increase which the grant increases would be provided. (approximately $230 million for a full year) and Providing COLAs to Maintain Desired Grant would result in the changes to the maximum grant Levels. Once SSI/SSP grants are at desired levels, reflected in Figure 4. the Legislature may also want to consider providing ongoing COLAs to Figure 4 maintain the purchasing SSI/SSP Monthly Maximum Grant Levelsa power of those grants. If Whole-Grant COLA Provided The Governor’s proposed 2016-17 Estimated COLA to the SSP portion 2015-16 Whole-Grant COLA Change of the grant—if provided Maximum Grant—Individuals annually—would be one SSI $733.00 $743.19 $10.19 way to achieve this goal. SSP 156.40 170.76 14.36 This approach takes the Totals $889.40 $913.95 $24.55 Percent of Federal Poverty Levelb 90% 92% view that it is the state- Maximum Grant—Couples funded SSP portion of SSI $1,100.00 $1,115.29 $15.29 the grant that should be SSP 396.20 422.21 26.01 maintained, while federal Totals $1,496.20 $1,537.50 $41.30 Percent of Federal Poverty Levelb 112% 115% COLAs would continue to a The maximum monthly grants displayed refer to those for aged and disabled individuals and couples living in their own adjust the SSI portion of households, effective as of January 1 of respective budget year. b Compares grant level to federal poverty guideline from the U.S. Department of Health and Human Services for 2016. the grant. 10 Legislative Analyst’s Office www.lao.ca.gov 2016-17 BUDGET Whatever the Funding Level, SSI/SSP sets its goals for the program, it can ensure that Grant Increases Could Be Structured to Further whatever the funding level provided for SSI/SSP Legislature’s Goals. As we have discussed above, grant increases—be it the $41 million proposed by there are various goals the Legislature may wish the Governor or some other amount—the funding to establish when considering SSI/SSP grant would be used in a way that furthers those goals. increases, all at various costs. Once the Legislature IN-HOME SUPPORTIVE SERVICES Background meet the state’s nursing facility clinical eligibility standards, the federal government provides an Overview of IHSS. The IHSS program provides enhanced reimbursement rate of 56 percent personal care and domestic services to low-income referred to as Community First Choice Option. The individuals to help them remain safely in their own nonfederal costs of the IHSS program are paid for homes and communities. In order to qualify for by the state and counties, with the state assuming IHSS, a recipient must be aged, blind, or disabled the majority of the nonfederal costs. and in most cases have income below the level Counties’ Share of IHSS Costs Is Set in necessary to qualify for SSI/SSP cash assistance. Statute. Budget-related legislation adopted in The recipients are eligible to receive up to 283 hours 2012-13 created a county maintenance-of-effort per month of assistance with tasks such as bathing, (MOE) for IHSS. The county MOE generally sets dressing, housework, and meal preparation. Social counties’ contributions to IHSS at their 2011-12 workers employed by county welfare departments levels, and increases the contributions annually by conduct an in-home IHSS assessment of an 3.5 percent (for inflation) plus a share of any wages individual’s needs in order to determine the and benefits subsequently negotiated at the county amount and type of service hours to be provided. level. Under the county MOE financing structure, The average number of service hours that will the state General Fund assumes all nonfederal be provided to IHSS recipients is projected to be IHSS costs above counties’ MOE expenditure approximately 102 hours per month in 2016-17. In levels. In 2016-17, the Governor’s budget estimates most cases, the recipient is responsible for hiring the total county MOE to be about $1.1 billion, an and supervising a paid IHSS provider—oftentimes increase of $37 million above the estimated county a family member or relative. MOE for 2015-16. The IHSS Program Receives Federal Funds as a Medi-Cal Benefit. For nearly all IHSS recipients, The Governor’s Budget Proposal the IHSS program is delivered as a benefit of the and LAO Assessment state-federal Medicaid health services program The budget proposes $9.2 billion (all funds) (known as Medi-Cal in California) for low-income for IHSS expenditures in 2016-17, which is an populations. The IHSS program is subject to federal approximately $700 million (8.3 percent) net Medicaid rules, including the federal medical increase over estimated expenditures in 2015-16. assistance percentage reimbursement rate for General Fund expenditures for 2016-17 are California of 50 percent of costs for most Medi-Cal proposed at nearly $3 billion, a net increase of recipients. For IHSS recipients who generally www.lao.ca.gov Legislative Analyst’s Office 11 2016-17 BUDGET $32 million, or 1.1 percent, above the estimated full-year impact of the state’s minimum wage expenditures in 2015-16. It is important to note increase from $9 to $10 per hour that began on that the modest year-over-year net growth in IHSS January 1, 2016. In addition, the budget reflects General Fund expenditures masks a number of wage increases negotiated at the county level both cost increases and savings. On the cost front, for IHSS providers. We note, however, that the the budget reflects caseload growth, higher costs Governor’s budget does not take into account per service-hour as a result of wage increases, and wages negotiated after September 2015, including increased costs for a full year of compliance with a county-negotiated wage increase from $10 to $11 new federal labor regulations. On the savings for Los Angeles County IHSS providers effective front, the Governor’s January budget proposes to February 1, 2016. We estimate the Los Angeles continue to restore IHSS service hours that were County wage increase will cost the General Fund eliminated as a result of a previously enacted approximately $70 million in 2016-17. We expect 7 percent reduction in service hours, but to do so that the Governor’s revised estimates released in through a restructured tax on MCOs rather than May will account for this and other negotiated through the General Fund, as was done in 2015-16 wage increases that occurred after the development (at a General Fund cost of $233 million). We note of the Governor’s budget, but are set to take effect that on February 8, 2016, the administration in 2016-17. released an updated MCO tax proposal. The Implementation of Federal Labor Regulations administration has indicated that funding to Affecting Home Care Workers. As shown in continue the IHSS service-hour restoration could Figure 5, the 2016-17 budget includes full-year come from either MCO tax revenues or the General funding ($850 million total funds, $395 million Fund. While we generally do not take issue with General Fund) to comply with federal labor the Governor’s budget proposal, overall, we note regulations that became effective in 2015-16. The that the budget includes several areas of fiscal new regulations require states to (1) pay overtime uncertainty. Below, we describe some of the main compensation—at one-and-a-half times the regular components of the Governor’s IHSS proposal and rate of pay—to IHSS providers for all hours worked note any issues with them. that exceed 40 in a week, and (2) compensate Increases in IHSS Basic Services Costs. IHSS providers for time spent waiting during Caseload growth and wage increases for IHSS medical appointments and traveling between providers continue to be two primary drivers of the homes of IHSS recipients. We note that 2014 increasing IHSS service costs. The Governor’s budget-related legislation generally restricts IHSS budget assumes the average monthly caseload for providers to work no more than 66 hours per week. IHSS in 2016-17 will be about 490,000, an increase Although these federal regulations were issued in of 5.7 percent compared to the estimated 2015-16 2013, legal challenges in the federal courts halted average monthly caseload. We have reviewed the implementation. In anticipation of a federal court caseload projections in light of actual caseload decision requiring implementation sometime in data available to date and do not recommend any 2015, the 2015-16 budget included partial-year adjustments at this time. Provider wage increases funding to implement the regulations (contingent also contribute to increasing IHSS service costs. on the courts’ validation), but did not specify an The Governor’s budget includes $70 million implementation date. Following a federal court General Fund ($150 million total funds) for a decision in August 2015 that affirmed the validity 12 Legislative Analyst’s Office www.lao.ca.gov 2016-17 BUDGET Figure 5 In-Home Supportive Services: Costs to Comply With New Federal Labor Regulations (In Millions) 2015-16 Estimates 2016-17 Governor’s Proposal (February 1, 2016 Implementation) (Full-Year Cost of Compliance) General Fund Total Funds General Fund Total Funds Overtime premium pay $164 $356 $218 $475 Newly compensable work activities 117 247 172 366 Administration 25 50 2 5 Changes to time sheet and payrolling system (CMIPS II) 6 11 2 4 Totals $312 $664 $395 $850 CMIPS II = Case Management, Information and Payrolling System. of the rules, the state set an implementation date • Limitations Placed on Overtime and of February 1, 2016 for the new regulations to take Newly Compensable Work Activities. effect in IHSS. Below, we discuss several elements The 2016-17 budget includes a full year of of the state’s implementation plan and highlight funding for IHSS provider overtime and any issues with them: newly compensable work activities. This • Current Year May Be Overbudgeted estimate reflects the statutory caps adopted in 2014—before federal courts placed a Due to Delayed Implementation. The temporary hold on implementation— 2015-16 budget assumed that the new generally limiting the number of hours federal labor regulations would be an IHSS provider can work to 66 hours implemented on October 1, 2015. Since per week. When multiplied by roughly then, the administration has established four weeks per month, this weekly an implementation date of February 1, limit is about equal to the maximum 2016. Rather than reduce the 2015-16 number of service hours that may be IHSS budget by an estimated $120 million allotted to IHSS recipients per month. General Fund to account for the The Governor’s budget estimates that implementation delay, the administration 28 percent of providers typically work has indicated that it made the decision to more than 40 hours per week, and that keep this funding in the budget to provide most of these providers generally work less for any unforeseen costs associated with than the new 66 hour per week cap. The the new regulations. We note that the legislation establishing the caps also limits methodology it used to estimate 2015-16 the amount of time an IHSS provider who expenditures related to implementation of works for multiple recipients can spend the new rules already provides contingency traveling between the homes of recipients funding to account for some level of to seven hours per week. We note that uncertainty. As a result, IHSS may be DSS estimates that of the approximately overbudgeted by around $120 million 18 percent of IHSS providers who serve General Fund in 2015-16. more than one recipient, most spend www.lao.ca.gov Legislative Analyst’s Office 13 2016-17 BUDGET under seven hours per week traveling 2015-16, we estimate that this exemption between recipients. These limitations will could result in General Fund costs in the be enforced by a tiered penalty system low millions of dollars annually. Until developed by DSS. Providers can be more guidance is issued about how the terminated if they violate these limitations extraordinary circumstances exemption on multiple occasions. may be applied, it is difficult to estimate its potential costs. • Exceptions to Overtime Limit for Certain Providers. After the 2016-17 Governor’s • Three-Month Grace Period for All budget was released, DSS issued guidance Providers. The legislation that enacted to counties establishing two exemptions the overtime and travel time limits for to the overtime cap: (1) an exemption for IHSS providers also established a grace live-in family care providers, and (2) a period for the first three months of temporary exemption for extraordinary implementation (now spanning February 1 circumstances. We note that current law through May 1, 2016). During this grace does not provide specific authority for period, providers will not accrue penalties these exemptions. It is our understanding if they violate the overtime and travel time that the administration will be seeking limits. County social workers, however, statutory authority for these exemptions may work with IHSS providers found through the budget process. The first violating the limits and inform them of the exemption is for IHSS providers who are violation without penalty during this time. related to, live with, and work for two or Proposed Continued Restoration of Service more IHSS recipients. For these providers, Hours From 7 Percent Reduction. Offsetting the the overtime cap is extended to 90 hours above increases in IHSS General Fund costs, the per workweek (not to exceed 360 hours Governor’s January budget proposes to use revenue per month). In 2015-16, it is estimated that from a restructured MCO tax, rather than General approximately 760 IHSS providers met Fund, in the amount of $236 million to provide the this criteria. For the second exemption nonfederal share of funding needed to continue to related to extraordinary circumstances, restore service hours from the 7 percent reduction DSS (in consultation with the Department enacted in 2013-14. In 2015-16, the service hours of Health Care Services), is in the process were restored through the use of the General of establishing criteria for temporarily Fund on a one-time basis, with the intent that exempting IHSS providers from the an alternative funding source would be used in 66-hour workweek limit in situations future years. The 7 percent restoration relates to where the limit would place IHSS recipients terms of an IHSS settlement agreement—adopted at risk of out-of-home institutionalized by the Legislature—that resolves two class-action care. At this time, the Governor’s budget lawsuits stemming from previously enacted budget does not include funding to account for reductions. The terms of the settlement agreement either of the two exemptions. Based on the require the state to pursue a revenue source other number of providers estimated to meet the than the General Fund for the purpose of restoring live-in family care provider exemption in service hours from the 7 percent reduction. On 14 Legislative Analyst’s Office www.lao.ca.gov 2016-17 BUDGET February 8, 2016, the administration released an funding source for the service-hour restoration could updated MCO tax proposal. As noted earlier, the be either MCO tax revenues or the General Fund. CALWORKS Background WTW 24-Month Time Clock Determines Allowable Activities. As of 2013, state law The CalWORKs program was created in defines two sets of rules for which allowable 1997 in response to 1996 federal welfare reform WTW activities may be used to meet the work legislation that created the federal Temporary requirement. The first set of rules, referred to as Assistance for Needy Families (TANF) program. “federal” rules because they closely mirror federal CalWORKs provides cash grants and employment TANF law, place greater emphasis on employment services to families whose income is inadequate to over some other activities including education, meet their basic needs. training, and mental health and/or substance Cash Assistance. Grant amounts vary across abuse treatment. The second set of rules, referred the state and are adjusted for family size, income, to as “CalWORKs” rules, allow relatively greater and other factors. For example, a family of three flexibility to choose activities that may help adult that has no other income and lives in a high-cost recipients address barriers to employment. Adult county currently receives a cash grant of $704 per recipients may meet the work requirement under month (equivalent to 42 percent of the federal federal rules at any time, but may meet the work poverty level). A family in these circumstances requirement under CalWORKs rules only for up would generally also be eligible for food assistance to a cumulative, but not necessarily consecutive, through the CalFresh program in the amount 24 months. Once 24 months of participation under of $497 per month and health coverage through CalWORKs rules have been exhausted, recipients Medi-Cal. must participate under federal rules. This policy is Work Requirement and Employment Services. referred to as the “WTW 24-month time clock.” As a condition of receiving aid, able-bodied adults Federal Work Participation Rate (WPR) are generally subject to a work requirement, Requirement. As noted above, federal law lays out meaning that they must be employed or participate rules governing how recipients may meet the work in specified activities—known as “welfare- requirement. Federal law requires the state to track to-work (WTW) activities”—intended to lead to the percentage of assisted families that meet the employment. CalWORKs cases that include an work requirement under federal rules, also known adult who is subject to the work requirement are as the WPR. Federal law further requires the state entitled to receive subsidized child care and other to maintain a WPR of at least 50 percent or face employment services to help meet the requirement. financial penalties. Individuals who fail to meet the work requirement Adult Time Limit on Aid. In California, adult without good cause are subject to a sanction recipients are also generally limited to a cumulative by being removed from the calculation of their lifetime maximum of 48 months of assistance in family’s monthly grant, resulting in reduction in CalWORKs. Adults who exhaust 48 months of cash cash assistance (of roughly $140 dollars). assistance are removed from the calculation of their www.lao.ca.gov Legislative Analyst’s Office 15 2016-17 BUDGET family’s monthly grant, resulting in decreased cash (specifically, an increase in state support for assistance. (The family would continue to receive a Tribal TANF programs). Within the total funding reduced grant for children who remain eligible.) amount, the budget proposes $741 million Funding. CalWORKs is funded through a in General Fund support for CalWORKs, an combination of California’s federal TANF block increase of $43 million (6 percent) over estimated grant allocation, the state General Fund, and current-year levels. This increase in General Fund county funds, including significant amounts spent support primarily reflects a net decrease in the by counties as a result of state-local realignment. amount of funding budgeted from non-General In order to receive its annual TANF allocation, Fund sources, thereby increasing the requirement the state is required to spend an MOE amount for General Fund. The following sections highlight from state and local funds to provide services to some major features of the 2016-17 CalWORKs families eligible for CalWORKs. In recent years, budget. this MOE amount has been $2.9 billion. While the Budget Estimates Reduction in CalWORKs program makes up the majority of Current-Law Funding Requirement TANF and MOE spending, it is important to note that the TANF block grant is used to fund a variety The budget estimates that the total funding of programs in addition to CalWORKs, and some required to operate CalWORKs consistent with state and local expenditures outside CalWORKs are current law and policy will decrease in 2016-17 counted toward the MOE requirement. relative to the prior year. Below, we describe two factors that contribute to the decreased funding Budget Overview requirement. As shown in Figure 6, the Governor’s budget Savings From Declining Caseload. The proposes $5.3 billion in total funding for the number of families receiving CalWORKs assistance CalWORKs program in 2016-17, a net decrease each month has generally declined since 2011-12, of $187 million (3 percent) relative to estimated primarily due to an improving labor market. The current-year funding. This decrease primarily budget estimates that the average monthly number reflects savings from a declining caseload, slightly of CalWORKs cases in 2015-16 will be 507,615—a offset by a small increase in other spending 5 percent decrease from the prior year. The average monthly number of cases Figure 6 is projected to further CalWORKs Budget Summary decline by 2 percent All Funds (Dollars in Millions) in 2016-17 to 496,558. Change From 2015-16 Consistent with these 2015-16 2016-17 Estimated Proposed Amount Percent caseload declines, the Cash grants $3,051 $2,963 -$88 -3% budget reflects savings Employment services 1,468 1,390 -78 -5 from a declining caseload Stage 1 child care 410 394 -16 -4 of about $165 million (all Administration 494 482 -12 -2 Othera 95 102 7 7 funds) in 2016-17 relative Totals $5,518 $5,331 -$187 -3% to the prior year. a Excludes transfer of federal Temporary Assistance for Needy Families block grant funds to the Cal Grant program and funding for the Kinship Guardianship Assistance Payment Program. 16 Legislative Analyst’s Office www.lao.ca.gov 2016-17 BUDGET Savings From Ongoing Implementation CalWORKs costs among the program’s major of the WTW 24-Month Time Clock. Adult funding sources, displayed in Figure 7. Below, we recipients who exhaust 24 months of participation describe some of the factors that contribute to these under CalWORKs rules may continue to receive shifts. assistance by meeting the work requirement Reduced Realignment Funding From Local under federal rules. However, some recipients who Indigent Health Savings. Current law directs exhaust the 24 months are anticipated to fail (for a certain realignment funds previously dedicated variety of reasons) to meet the work requirement to local indigent health programs to instead be under federal rules, resulting in reduced cash used each year to pay for an increased county assistance. The first individuals to exhaust the share of CalWORKs grant costs, in an amount 24 months, fail to meet the work requirement equal to the estimated savings that counties will under federal rules, and have their assistance realize in their indigent health programs due to reduced, are beginning to do so during 2015-16, the expansion of Medi-Cal. This redirection of with the number expected to grow over the next funds reduces the amount of state and federal several years before leveling off. Specifically, funds needed to support the CalWORKs program. the administration estimates that 1,790 cases (For more information on this redirection, see the (0.4 percent of the total caseload) will have reduced “CalWORKs” write-up in our previous report, The cash assistance by the end of 2015-16 with an 2014-15 Budget: Analysis of the Human Services estimated savings of $1 million (all funds), growing Budget.) Current law also provides that the state to 11,650 cases (2.4 percent of the total caseload) “true up” the amount of redirected savings three and savings of roughly $11 million (all funds) by years after the fact to reflect actual county savings the end of 2016-17. amounts. For 2016-17, the budget estimates that the amount of CalWORKs grant costs paid with Shifts in Program Funding Sources realignment funds from local health savings will Within the estimated total funding be $413 million, which is $329 million (44 percent) requirement of the program in 2016-17, the less than estimated for 2015-16. The main reasons Governor’s budget reflects some shifting of total for the significant reduction in estimated savings Figure 7 CalWORKs Funding Sources (Dollars in Millions) Change From 2015-16 2015-16 2016-17 Estimated Proposed Amount Percent Federal TANF block grant fundsa $2,574 $2,684 $110 4% General Fundb 698 741 43 6 Realignment funds from local indigent health savings 742 413 -329 -44 Realignment funds dedicated to grant increases 311 302 -9 -3 Other county/realignment funds 1,193 1,191 -2 —c Totals $5,518 $5,331 -$187 -3% a Excludes transfer of federal Temporary Assistance for Needy Families (TANF) block grant funds to the Cal Grant program. b Excludes funding for the Kindship Guardianship Assistance Payment Program. c Rounds to zero. www.lao.ca.gov Legislative Analyst’s Office 17 2016-17 BUDGET are (1) data from counties show that the state’s the difference and no additional grant increase is estimated savings in 2013-14 were likely overstated, provided. The amount of General Fund support requiring the state to return an estimated needed to make up for insufficient dedicated funds $151 million to counties through the true-up in 2016-17 is $17 million. process during 2016-17, and (2) the administration Increased General Fund Needed to Backfill now has lower expectations for the amount of Reduced Realignment Funding and Meet MOE annual ongoing savings. Decreased realignment Requirement. As noted above, the state must funding from local health savings increases the pay a minimum MOE amount from state and need for funding from other sources. We note that local funds (including realignment) to receive the estimated local indigent health savings for 2016-17 annual TANF block grant. The reduction in the are uncertain and may be updated at the May estimated current-law funding requirement and the Revision. estimated decrease in available realignment funds Realignment Funds Dedicated to Grant from local health savings mean that General Fund Increases Insufficient for New Increase. Current spending in CalWORKs must increase for the state law dedicates certain other realignment funds to to meet the required MOE in 2016-17. Specifically, pay the costs of new CalWORKs grant increases General Fund support for CalWORKs increases by and outlines an annual process through which $43 million (6 percent) in 2016-17 over the prior these grant increases are provided. Unlike year. realignment funds from local health savings, Increased Federal TANF Support From discussed above, these dedicated funds are not Carry-In. The budget estimates that the amount of intended to offset the funding needed from unused TANF funding available for use in 2016-17 other sources. Rather, dedicated funds are increased by roughly $400 million over the prior intended to cover increases to total program costs year, largely from funds allocated to counties in resulting from new grant increases. Specifically, prior years that were not spent. After accounting for each year the Department of Finance (DOF) the increased General Fund support needed to meet estimates the combined cost of all past increases the state’s MOE requirement, only $110 million of provided from the dedicated funds (two separate these additional TANF funds are needed to meet 5 percent increases have been provided to date, in the estimated current-law funding requirement of March 2014 and April 2015, at a total annual cost of the program. The budget increases TANF support $319 million during 2016-17) and the total amount for CalWORKs by this amount and increases the of available dedicated funds ($302 million in amount of TANF funds used to support financial 2016-17). When the estimated amount of dedicated aid for low-income college students through the Cal funds exceeds the estimated cost of previously Grant program by $304 million, directly offsetting provided increases, DOF further determines what otherwise would be General Fund Cal Grant the percentage increase in CalWORKs grants costs of the same amount. that could be sustained by the excess dedicated State Has Likely Reached WPR Compliance funds. A grant increase of this amount would then be provided during the budget year. When California Has Failed to Meet WPR the estimated cost of previous grant increases Requirement Since 2007. California has failed to exceeds the estimated amount of dedicated funds, meet the WPR requirement every year since federal as is the case for 2016-17, the General Fund covers fiscal year (FFY) 2006-07 and has been assessed 18 Legislative Analyst’s Office www.lao.ca.gov 2016-17 BUDGET cumulative penalties of about $1.3 billion, as shown Figure 8 in Figure 8, that would ultimately take the form Work Participation Rate Penalties of a one-time reduction to the state’s TANF block (In Millions) grant allocation. To date, the state has not faced FFY Penalty any reductions to the TANF block grant as the state 2007-08 $48 pursues various administrative avenues to reduce 2008-09 113 or eliminate the penalties. 2009-10 180 Federal Law Allows WPR Penalties to Be 2010-11 246 2011-12 312 Reduced or Eliminated Through Corrective 2012-13 378 Compliance Plans. Federal law provides that Total $1,277 penalties may be eliminated if a state enters Note: The state failed to meet the work participation rate requirement in federal fiscal year (FFY) 2013-14 but has not yet into a “corrective compliance plan” that results been assessed any additional penalties. in the state meeting the WPR requirement in a later year. To date, the state has submitted two Analyst’s Budget Assessment corrective compliance plans. Under the first, Governor’s Proposal Consistent With Current $342 million in penalties for 2007-08, 2008-09, Law and Policy. In our view, the Governor’s and 2009-10, would be eliminated if the state 2016-17 CalWORKs budget proposal is consistent meets the WPR requirement during FFY 2014-15 with current law and policy and makes adjustments (which ended in October 2015). Under the second, to total funding only to reflect costs and savings $558 million in penalties for 2010-11 and 2011-12 associated with changes in caseload and ongoing may be eliminated if the state meets the WPR implementation of previously enacted policy requirement during FFY 2015-16. The state has not changes. yet submitted a corrective compliance plan for the Caseload Estimates Generally Appear 2012-13 penalties. Reasonable, but Should Be Revisited at May California Likely Reached Compliance in FFY Revision. The CalWORKs budget is largely driven 2014-15. With the release of the Governor’s budget, by assumptions made by the administration the administration announced that it appears to about the number of families that will receive have achieved a WPR of 55 percent—sufficient for assistance and what services they will need. In compliance—during FFY 2014-15. If compliance examining the Governor’s proposal, we reviewed is verified by the federal government, $342 million the administration’s caseload estimates against the of the state’s penalties will be eliminated. If most recent actuals available and our expectations compliance is maintained in 2015-16, most of the for how caseloads may change in the future. In our penalties assessed for 2010-11 and 2011-12 will be view, the administration’s estimate of the number eliminated. (A small portion of 2011-12 penalties of families that will receive cash assistance and relate to an additional WPR requirement for cases the families that will utilize child care subsidies with two parents that the state continues not to appear reasonable. We note that the estimated need meet. These penalties will need to be addressed for other employment services may be overstated through other means.) We note that the state failed (implying that savings on services may be greater to meet the WPR requirement in 2013-14, but than assumed in the Governor’s budget). However, penalties for that year have not yet been assessed. we recommend leaving caseload-related funding www.lao.ca.gov Legislative Analyst’s Office 19 2016-17 BUDGET decisions until after the May Revision. Our office estimates and associated budgeted funding levels will follow actual caseload levels between now and should be made. May to assess whether any updates to the caseload CONTINUUM OF CARE REFORM California’s child welfare system serves to Overview of the Child protect the state’s children from abuse and neglect, Welfare System often by providing temporary out-of-home California’s child welfare system provides placements for children who cannot safely remain a continuum of services for children who have in their home and services to safely reunify experienced or are at risk of experiencing abuse or children with their families. As part of a years-long neglect. These child welfare services (CWS) include effort to identify and effect improvements to the responding to and investigating allegations of state’s child welfare system, the Legislature passed abuse and neglect, providing family preservation legislation in 2015 implementing the Continuum services to help families remain intact, removing of Care Reform, or CCR. The law, Chapter 773 of children who cannot safely remain in their home, 2015 (AB 403, Stone), makes fundamental changes and providing temporary out-of-home placements to the way the state cares for children who have until (1) the family can be successfully reunified been removed from their home. Predicated on or (2) an alternative permanent placement can be widespread concern surrounding poor outcomes found. Adoption and guardianship are the two for children placed in non-family-like settings, most common permanent placement options after CCR aims to increase the foster care system’s family reunification. reliance on more family-like settings rather Child Welfare Programs Are State Supervised, than institutional settings like group homes. County-Administered. The DSS oversees CWS, Additionally, CCR makes changes to ensure that while county welfare departments carry out the state’s foster children receive needed mental day-to-day operations and services. DSS is health treatment and supportive services regardless responsible for statewide policy development, of their placement setting. enforcing state and federal regulations, and To accomplish these goals, the Governor’s ensuring that the state achieves the federal budget proposes about $60 million in General performance standards tied to federal funding. Fund for support of CCR implementation efforts. Counties have some flexibility around the design While the long-term fiscal implications of CCR are of their operations and the range of services they unknown, the Governor’s 2016-17 budget recognizes provide. All counties investigate allegations of that CCR implementation requires up-front funding abuse, engage with families to help them remain from the state. This analysis begins by providing intact, and provide maintenance payments to an overview of the existing foster care system; foster caregivers and providers. Other services vary highlights the major policy changes included in county by county, with some counties, for example, AB 403; and evaluates the Governor’s proposed offering supplemental payments for children with CCR implementation spending in light of continued high needs and others offering child care for a uncertainties around the ultimate costs, savings, and subset of children in care. Assisting the counties programmatic impacts of the reform package. 20 Legislative Analyst’s Office www.lao.ca.gov 2016-17 BUDGET are several hundred private Foster Family Agencies the nonfederal costs of administering CWS. In (FFAs) and group home operators who themselves 2011, the state enacted legislation known as 2011 provide a continuum of services ranging from realignment, which dedicated a portion of the foster parent recruitment and certification to state’s sales tax to counties to administer CWS. mental and behavioral health counseling. The 2016-17 budget assumes that over $2 billion The Role of County Probation Departments will be available from realignment revenues for the in the Child Welfare System. County probation support of CWS programs. The 2011 realignment departments carry out many of the same services transferred fiscal risk to counties at the same time provided by county welfare departments in the as it gave them a guaranteed source of revenues. case of children who have been declared wards Prospectively, counties are not responsible for of the court through a delinquency hearing. future cost increases resulting from state, federal, After obtaining jurisdiction over a child, county and judicial policy changes, but are responsible for probation departments will assess the parents’ all other increases—for example, those associated ability to adequately supervise the child, provide with rising caseloads. Conversely, if overall child family preservations services if there is a risk of welfare costs fall, counties get to retain those removal, and secure a foster care placement— savings. Proposition 30, approved by voters in typically in a group home—if removal is deemed 2012, protects the state from having to reimburse necessary. Unlike the majority of children counties for child welfare policies that were in place who enter the child welfare system, children in prior to 2011 realignment. Proposition 30 also out-of-home care due to a probation decision protects counties by establishing that counties only have not necessarily been subject to abuse or need to implement new state policies that increase neglect. Instead, probation departments typically overall program costs to the extent that the state utilize foster care placements with the aim of provides funding. rehabilitating the child. Commonly considered a Federal Funding for CWS. Federal funding for less restrictive setting for a population that might CWS stems from several sources and is estimated otherwise be placed in a locked facility, group to be over $2.5 billion in 2016-17. homes are the most utilized foster care placement State General Fund Supports Nonrealigned setting for county probation departments. In Components of Child Welfare and State Oversight contrast, child welfare departments utilize group Functions. The 2016-17 budget proposes over home placement relatively infrequently. Relative $250 million General Fund to county welfare and to children overseen by the child welfare system, probation departments to implement components probation youth tend to be older and require of the child welfare program that were not part heightened supervision. of 2011 realignment. This includes funding for such things as a program to combat the CWS Funding commercial sexual exploitation of children and Total funding for CWS is estimated to be foster care payments for certain relative caregivers. roughly $5 billion for 2016-17. Below we describe Additionally, the General Fund continues to the major sources of this funding. support the state’s CWS oversight function at DSS. 2011 Realignment Revenues Are a Major Source of CWS Funding in the State. Until 2011-12 the state General Fund and counties shared www.lao.ca.gov Legislative Analyst’s Office 21 2016-17 BUDGET Child Welfare Workers Rely on an Array supervision payment rates from the state—which of Out-of-Home Placement Options we refer to as foster care payment rates. Kinship Care. Established child welfare policy When finding a placement for foster children, and practice in the state prioritizes placement counties rely on four primary placement options— with a noncustodial parent or relative. Among kinship care, foster family homes (FFHs), FFAs, child welfare workers’ first responsibilities and group homes. As of October 2015, there were following a child’s removal is locating a potential over 65,000 children in foster care in California. relative caregiver. Kinship care comprises care For this report we refer to kinship care, FFHs, from relatives and nonrelative extended family and FFAs as home-based family care. Federal and members and is the state’s most utilized placement state law mandate that children be placed in the option at 38 percent of foster placements as of least restrictive placement setting, which state October 2015. Unlike other placement types, law describes as that which promotes normal kin-caregivers are not necessarily eligible for childhood experiences and the day-to-day needs of foster care payments at the same level as other the child. Figure 9 shows the proportions of foster foster caregivers. Specifically, relatives caring for children in each of these placement settings. The children who are ineligible for federal financial four selected placement types vary in their level participation (primarily due to income eligibility of restrictiveness, serve children with different rules) have historically received a lower foster though overlapping needs, provide distinct sets of care payment rate—the CalWORKs child-only specialized services, and receive varying care and payment of $369 per child per month in 2015-16. However, with the passage of Figure 9 the state-funded Approved Distribution of Foster Children by Selected Placement Typea Relative Caregiver (ARC) funding option program in 2014, relative caregivers of federally ineligible children FFA Kinship Care can potentially receive the foster care payment rate (referred to as the basic rate), which varies in 2015-16 from $688 to $859 per month based on the age of the child. The Otherb ARC program is optional at the county level and several counties have chosen not to Group Home FFH participate; as a result, some relative caregivers continue to a Data Source: University of California, Berkeley California Child Welfare Indicators Project. b “Other” includes foster children living in placements other than the four selected placements, receive the lower CalWORKs for example, children placed in Supervised Independent Living Placements and Transitional Housing. The category excludes children placed with guardians who nevertheless have an rate. Currently 47 counties open child welfare case. have opted to participate in FFH = foster family home and FFA = foster family agency. the ARC program. 22 Legislative Analyst’s Office www.lao.ca.gov 2016-17 BUDGET FFHs. County-licensed foster homes, known supervision, and services to foster children with as FFHs, are often the preferred placement option the highest levels of need, often children with when a suitable relative caregiver cannot be found significant emotional or behavioral challenges who and the child does not have needs requiring a have difficulty achieving stability in a home-based higher level of services. Counties recruit FFH family setting. Professional staff provide the caregivers and provide basic social work services care and supervision as well as therapeutic and to the approximately 10 percent of foster children supportive services to children in group homes. statewide who resided in an FFH as of October Due in part to the absence of a parental caregiver, 2015. In 2015-16, FFH caregivers receive the group homes are considered the most restrictive foster care payment basic rate of $688 to $859 per (except in the case of foster children supervised month (varying by the child’s age) for the care and by probation agencies), least family-like foster supervision of each foster child in their home. care setting, and are generally the least preferred FFAs. The FFAs are the only primary placement option. Because of their reliance on placement type that does not directly house the professional staff and provision of often intensive children under their care. Instead, FFAs are private supportive services, group homes are compensated nonprofit agencies that recruit and certify foster at higher rates than the other placement types. caregivers, place children into FFA-certified homes, The Rate Classification Level System (RCL), which and provide supportive services to the children in features 14 rate levels, determines group home their care, typically children with elevated needs provider payments. For 2015-16, providers receive compared to those placed in FFHs. Considered between $2,391 (RCL 1) to $10,130 (RCL 14) a less restrictive alternative to group home care, per month per child, depending primarily on placement in an FFA is often the preferred option the qualifications of their staff and the number for children whose placement stability depends on of staff hours they provide to children in their greater social worker involvement and direct access care. Services and treatments vary across group to supportive services. Because they offer a wider homes, but often include, particularly among array of services and typically serve children with higher level group homes, counseling and mental higher needs, counties reimburse FFAs at a higher health treatment services. As of October 2015, rate than either relative caregivers or FFHs. The approximately 10 percent of California’s foster FFA-certified caregivers receive the basic rate plus children were living in group homes. a $189 monthly supplemental payment known as Other Placement Types. In addition to the four the Child Increment. On top of this, FFAs are paid primary placement types described above, a suite a monthly rate between $912 and $1,012 per child of alternative options exist to serve children with for the social work and administrative services they distinct needs and circumstances. For example, these provide. Adding together the direct caregiver and include supervised independent living arrangements FFA portions, the payment per child placed at an for older, relatively more self-sufficient youth. FFA in 2015-16 ranges from $1,789 to $2,060 per Summary of Monthly Foster Care Provider month (referred to as the FFA rate). As of October Rates. Figure 10 (see next page) summarizes the 2015, 27 percent of the state’s foster children were foster care payment rate structure for the four placed through an FFA. primary placements types. Each carries different Group Homes. Group homes—operated as costs for the state and its federal and county funding private, nonprofit agencies—provide 24-hour care, partners. www.lao.ca.gov Legislative Analyst’s Office 23 2016-17 BUDGET Figure 10 Selected Monthly Foster Care Payment Rates by Placement Type 2015-16 Kin Caregivers Relative Non-Relative Foster Family Foster Family Caregivers Caregivers Homes Agencies Group Homes Foster care payment rate $369 or $688-$859a $688 - $859 $688 - $859 $688 - $859 $2,391 - $10,130b Supplemental caregiver Specialized Care Specialized Care Specialized $189 — payments Incrementc Incrementc Care Incrementc Supplemental provider — — — $912 - $1,012 — payments a Relative caregivers caring for a child who is ineligible for federal financial participation and who live in a county that has chosen not to participate in the Approved Relative Caregiver Program receive the $369, CalWORKs child-only rate. All other relative caregivers receive the basic rate. b Unlike home-based care providers who primarily receive a rate based on the age of the child, group home rates are determined by the level of services they provide. Rate Classification Level (RCL) 14 is the highest level and most costly group home; RCL 1 is the least costly. Children are assigned to group homes based on the level of their service needs. c The specialized care increment is a monthly supplemental payment available to kin and foster family homes caregivers at the county option for the care of children with elevated needs. Impetus for CCR family, others leave the foster care system with no life-long family relationships. We note that given Longstanding concerns about the outcomes the potentially higher needs of children placed in and costs of group home care led the Legislature group homes, it is difficult to determine whether to enact CCR legislation to reform the foster care group home placements themselves directly lead to system. CCR aims to reduce reliance on group these poor outcomes. homes and increase the capacity of home-based Group Homes Are More Costly Than family placements. Home-Based Family Placements. As previously Children in Group Homes Experience Poor noted, group home placements can cost up to Outcomes. The foster care system provides services $10,130 per child per month depending on the level for children from a variety of circumstances, each of care provided. In contrast, foster care payments with varied strengths and needs. Those placed for home-based family settings generally range in group homes tend to be children with higher from $688 per child per month for relative and FFH needs than the foster care population as a whole. placements to $2,060 for FFA placements. We note, Research suggests that group home placements are however, that there are certain home-based family occasionally warranted, but long-term group home placements, such as Intensive Treatment Foster stays are associated with elevated rates of reentry Care (ITFC), that have significantly higher payment into foster care, lower educational achievement, rates due to the level of services they provide. and higher rates of involvement in the juvenile Placing children in group homes when they could justice system. Children placed in group homes be successfully served in home-based family remain in foster care longer and often have a settings may not only be less effective, but also a more limited array of permanency options than less efficient use of child welfare resources. their home-based family placed peers. Those Concerns About the Adequacy of Home-Based who do not reunify with their families typically Family Placements. Reducing reliance on group emancipate by aging out of foster care. Although home placements has been a priority for the a portion of children who age out of group homes state for some time. One major challenge to may reconnect with their parents and extended 24 Legislative Analyst’s Office www.lao.ca.gov 2016-17 BUDGET reducing reliance on group home placements is Major Changes having an adequate supply of home-based family Resulting From CCR placements, particularly those capable of caring for children whose elevated needs make them CCR Creates a New Placement Type at risk for group home placement. Additionally, Short-Term Residential Treatment Centers services and supports to enable home-based family (STRTCs) Replace Group Homes. Assembly caregivers to care for children at risk of group Bill 403 seeks to end group homes generally as home placement are not available to all home-based a placement option beginning January 1, 2017. family placement types, in some cases requiring (With certain exceptions on a case-by-case basis, children to move to more restrictive settings in some group homes may be allowed to continue order to receive necessary mental health and other to operate as group homes past January 2017.) supportive services. Ensuring the adequacy and STRTCs will replace group homes as the placement availability of home-based family placements is setting for children who cannot safely be placed in a key consideration if reliance on group home home-based family settings, providing a similar placements is to be further reduced. level of supervision as group homes, but with Years of Legislative Interest Leads to expanded services and supports. In contrast to Reforming the State’s Foster Care System. group homes serving as long-term placements for Longstanding concerns surrounding poor children for whom home-based family placements outcomes for children growing up in group cannot be found, STRTCs are intended to provide homes led the Legislature in 2012-13 to call for the short-term, intensive treatment to allow children creation of a stakeholder workgroup to recommend to successfully transition to a family setting as changes to the foster care system—known as quickly and successfully as possible. Assembly CCR. Chapter 35 of 2012 (SB 1013, Committee Bill 403 restricts STRTC placements to children on Budget and Fiscal Review) instructed the who have been assessed as requiring the level of workgroup to develop revisions to the services behavioral and therapeutic services that STRTCs available to children in out-of-home care as well as will be required to provide. Children whose level the rate systems that govern foster care payments. of need qualifies them for STRTC placement In 2015, DSS published its legislative report with include, among others, those assessed as seriously 19 recommendations based on the workgroup’s emotionally disturbed and victims of commercial findings. The 19 recommendations aim to improve sexual exploitation. To ensure the ongoing the experience and outcomes of children in appropriateness of all STRTC placements, resident foster care and have largely been incorporated children’s case plans will be subject to review every into AB 403. The CCR centers around several six months by the director or deputy director of complementary goals—(1) ending long-term the supervising county child welfare or probation group home placements, (2) increasing access to department. The case plans will specify the reasons supportive services regardless of whether a child for the child’s placement, the expected duration of is in a group home or home-based family setting, stay, and the transition plan for moving the child to (3) utilizing universal child and family assessments a less restrictive environment. to improve placement and service decisions, and (4) increasing transparency and accountability for child outcomes. www.lao.ca.gov Legislative Analyst’s Office 25 2016-17 BUDGET CCR Efforts to Increase Access to Quality Improvement and Necessary Services and Supports Oversight Under CCR CCR Expands the Set of Core Services FFAs STRTCs and FFAs Required to Obtain and STRTCs Are Required to Provide. Among National Accreditation. CCR seeks to improve other activities, FFAs currently engage in foster the quality of residential services by requiring parent recruitment, retention, and certification, all STRTCs and FFAs to maintain accreditation and employ social workers to support the children from a nationally recognized accreditation body. in their care through more frequent interactions Accreditation typically involves an in-depth review than county social workers have historically been of an organization in order to confirm it meets funded to provide. (We note AB 403 also authorizes recognized service standards. Reaccreditation will counties to operate their own FFA.) Group homes, reoccur every three years as a means of ensuring particularly high-level ones, administer a range of continuous quality improvement and maintenance therapeutic and supportive services in addition to of high operating standards into the future. providing direct care and supervision. Under CCR, FFA and STRTC Performance Measure STRTCs and FFAs will be required to ensure access Dashboard for County Placement Agencies and to specialty mental health services and strengthen the Public. CCR calls for the development and their permanency placement services by approving promulgation of publicly available FFA and STRTC families for adoption, providing services to help performance measures. DSS intends for these families reunify, and giving follow-up support indicators—for example, on rates of successful to families after a child has transitioned to a less family reunifications, placement stability, client restrictive placement. Assembly Bill 403 requires satisfaction, educational achievement, and health several other core services to be made available, and safety standards—to inform placement including, but not limited to, educational, health, decisions. Assembly Bill 403 specifies January and social supports. The specifics around the new 2017 as the launch date for the public dashboard. core services that FFAs and STRTCs will have to Initially, the indicator dashboard will likely feature directly or indirectly provide is currently under only a subset of the measures that will ultimately development. be included, and then be gradually expanded as CCR Calls for Additional Integration Between the system undergoes continued development and Child Welfare and Mental Health Services. Prior additional FFA and STRTC performance data to CCR, the state was working to ensure that become available. CWS-involved children obtain medically necessary CCR Changes to the Caregiver Approval mental health services. CCR builds on these and Placement Processes efforts by requiring all FFAs and STRTCs to either (1) maintain certification from the Department of Resource Family Approval (RFA) Replaces Health Care Services (DHCS) or county Mental the Existing Multiple Approval, Licensing, and Health Plans (MHPs) to provide mental health Certification Processes for Home-Based Family services directly or (2) contract with mental health Caregivers. Before foster caregivers may receive providers to serve children in their care. foster care payments, they must be approved, certified, or licensed to provide care. Currently, the approval process differs by placement type—for 26 Legislative Analyst’s Office www.lao.ca.gov 2016-17 BUDGET example, FFHs are licensed according to one set will be administered by a child welfare worker, the of criteria while relative caregivers are approved results of which will inform decisions made by the under a different set. The CCR replaces the multiple child and family team. approval standards currently in place with a CCR’s New Requirements Lead to the unified assessment that incorporates a psychosocial Development of New Rate Structures evaluation, risk assessment, and permanency assessment for all prospective home-based New STRTC and FFA Payments Rates family caregivers. Unlike the previous multiple, Are Currently Under Development. Generally, overlapping approval processes, the RFA process pursuant to AB 403, the RCL system featuring will automatically qualify a foster family for 14 separate group home reimbursement rates guardianship and adoption. Once the transition to and the current FFA rate structure will sunset RFA is complete, all home-based family placements and be replaced by a new set of rates that will will be approved as “resource families.” Currently take effect beginning January 2017. These new underway in five early-implementer counties, the rates are expected to reflect the expanded set of rest of the state will convert to the resource family responsibilities CCR places on STRTCs and FFAs. approval process for all new home-based family Under consideration by DSS and a stakeholder caregivers on or before January 1, 2017. workgroup is a system whereby a child’s needs More Collaborative, Child-Centered Decisions assessment determines, at least in part, the rate Through the Use of Child and Family Teaming. To that the child’s caregiver and supportive service increase child and family involvement in decisions provider(s) are entitled to. This could potentially relating to foster children’s care, CCR mandates allow, for example, a county to contract or provide the use of child and family “teaming” through supportive services for children in home-based every stage of the case planning and service family placements other than FFA-certified delivery process. The child and family team may homes. This would be in contrast to the current include, as deemed appropriate, the affected child, foster care payment rate system whereby a child’s her or his custodial and noncustodial parents, placement generally determines the foster care extended family members, the county caseworker, payment rate and services that the child receives. representatives from the child’s out-of-home Rate development remains a fluid process, however, placement, the child’s mental health clinician, and it is unknown at this time how rates will and other persons with a connection to the child. be structured in a way that increases access to Members of the team will meet as needed to discuss services for all children in home-based family and agree on the child’s service plan whenever an settings. Stakeholder workgroups focused on rate important foster care decision is being made. development are currently meeting, and it is our Needs Assessment to Inform Placement understanding that a new rate system will be ready and Services Decisions. CCR calls for children in March 2016. to receive a comprehensive strengths and needs Overview of the assessment upon entering the child welfare system Governor’s Budget for CCR to improve placement decisions and ensure prompt access to supportive services when they The Governor proposes $61 million from the are determined to be necessary. The assessment is General Fund ($95 million total funds) to continue expected to utilize a structured assessment tool that to implement CCR in 2016-17. The proposed www.lao.ca.gov Legislative Analyst’s Office 27 2016-17 BUDGET General Fund spending represents an increase of of children out of group homes into home-based $39 million over the $22 million General Fund family placements. The total funding proposed ($34 million total funds) provided for CCR in from the General Fund for CCR implementation 2015-16. We note that the 2015-16 funding for for counties in 2016-17 is less than it would be CCR is allocated primarily toward foster parent if these county savings were not assumed by the recruitment and retention and a rate increase for budget. It is important to note that the offsetting FFAs. As with 2015-16, most of the Governor’s county savings associated with CCR are accounted proposed spending for 2016-17 is dedicated to the for in this way due to 2011 realignment, which, as county child welfare and probation departments we previously discussed, established that the state that directly administer CWS, with a small must provide funding to counties equivalent to portion of the proposed funding for additional the net cost of new state policy requirements. We positions at DSS and DHCS to provide regulatory, describe the Governor’s estimated CCR costs and implementation, and administrative support to savings in more detail below. their county partners. Figure 11 summarizes how Over Half of the Governor’s Proposed Spending the proposed state CCR implementation spending is Is for Foster Parent Recruitment and Support. allocated among the various state and local entities. Reducing the state’s reliance on group home and STRTC placements depends on FFA and child Proposed CCR Spending Includes New welfare and probation departments’ ability to Assumed Costs and Savings for recruit and retain home-based family caregivers for County Implementation the children expected to leave group homes over The Governor’s proposed budget provides the next several years. The 2015-16 budget provided funding for the next round of CCR implementation. $17.2 million General Fund ($25.8 million total Most major components of AB 403 become funds) to support county efforts to increase the effective on January 1, 2017, requiring significant supply of home-based family caregivers. To receive implementation efforts by the state, counties, and recruitment and retention funds, county child foster care providers in advance of that date. The welfare and probation departments had to submit Governor’s 2016-17 proposed budget recognizes county plans to DSS identifying how they would new state General Fund costs associated with CCR use the funds to train, recruit, retain, and support implementation and accounts for offsetting county home-based family caregivers. In 2015-16 allowable savings from the elimination of duplicative foster uses of the funding provided to these county caregiver approval processes and the transition departments included: (1) staffing to provide direct Figure 11 2016-17 Proposed Continuum of Care Reform State Spending (In Millions) 2015-16 2016-17 General Fund Estimated Proposed Change Local assistance to county welfare and probation departments $21.5 $57.5 $36.0 Department of Social Services—state support 0.5 3.0 2.5 Department of Health Care Services and local assistance to — 0.4 0.4 county mental health plans Totals $22.0 $60.8 $38.8 28 Legislative Analyst’s Office www.lao.ca.gov 2016-17 BUDGET services and supports to foster caregivers, (2) foster however, all home-based family placements will care payment supplements to support caregivers of have to convert to RFA, which will require the children with exceptional needs, and (3) intensive reassessment of existing foster and kin caregivers. relative finding and engagement. Budget-related Funding for Proposed Child and Family legislation in 2015-16 requires DSS to report to Teaming (CFT) Activities. The CCR requires the the Legislature during 2016-17 budget hearings on use of a multidisciplinary, team-based approach to counties’ uses of these funds as well as the outcomes placement and other decisions that affect a child achieved. For 2016-17, the Governor builds on receiving CWS. The Governor’s budget recognizes the 2015-16 appropriation, proposing a total of that this new approach increases workload at the $32 million General Fund ($47 million total funds) county level since it requires the coordination to help counties increase the supply of high-quality, of team-based decision-making among multiple home-based family placements. About half of parties. After accounting for the components of 2016-17’s proposed spending is intended for county CFT that were in place before 2011 realignment and probation departments, which in 2015-16 received therefore already incorporated into county funding, a small fraction of the recruitment and retention the Governor’s budget includes $10 million General funding. At this time it is unclear whether the Fund ($14.4 million total funds) for a half year of proposed 2016-17 funds will be allocated to counties implementation for this component of CCR. using the same methodology used in 2015-16. Remaining Proposed Funding for a Variety of RFA Implementation Results in Net Costs. CCR-Related Activities. The remaining $11 million The Governor proposes $11 million General Fund General Fund ($18 million total funds) proposed ($16 million total funds) to assist counties as they for CCR implementation at the county level in transition to the unified RFA process. This funding 2016-17 is intended to (1) maintain the FFA rate represents the estimated net cost to counties of increase enacted in 2015-16 given caseload growth, implementing RFA after accounting for assumed (2) implement needs assessments and STRTC case total county savings of roughly $19 million in reviews, (3) help cover a portion of initial FFA and 2016-17. On the cost side, RFA imposes additional STRTC accreditation costs, (4) update child welfare training requirements on home-based family workers’ case management system, and (5) develop caregivers and expands the set of assessment the provider performance indicator dashboard. criteria that child welfare workers have to apply Also included in the Governor’s proposal is before approving a caregiver as a qualified approximately $200,000 General Fund ($400,000 placement. On the savings side—and among other total funds) for county MHPs to ensure children in expected efficiencies—the switch to RFA eliminates STRTCs are appropriately placed. the need to carry out adoption assessments Savings Due to Lower Foster Care Payments for caregivers already approved as resource Expected to Materialize in 2016-17. While the families and is expected to encourage placement Governor’s proposal does not provide a long-term stability, thereby reducing the total number of outlook for CCR-related General Fund costs, caregiver approvals by incorporating permanency the 2016-17 CCR proposal assumes that county considerations into the initial placement decision. savings related to lower foster care payments, The transition to RFA will be a multiyear effort which offset the above estimated costs, begin to as counties initially need only apply RFA to accrue in 2016-17. These savings are due to an new home-based family placements. By 2019, assumed steady transition of about 2,500 children www.lao.ca.gov Legislative Analyst’s Office 29 2016-17 BUDGET out of group homes into less costly home-based proposal that will be implemented by counties (that family placements over the first three years after is, apart from state operations expenditures). CCR becomes effective. For 2016-17, the Governor State Operations Spending projects $6.4 million in county savings as a result of shifting children to less costly placements, The Governor Proposes New Positions at DSS which offset the General Fund contribution that and DHCS for CCR Implementation. In 2015-16, would otherwise be necessary to implement CCR’s DSS received $500,000 for two new positions to other mandated activities. We note that although administer the foster parent recruitment, retention, CCR requires a new rate structure for STRTCs and support funding. The 2016-17 proposed and FFAs, these new rates were still under budget requests temporary funding (three years) development at the time of the Governor’s budget. of $2.5 million in General Fund ($5 million total In the absence of new rates for STRTCs and FFAs, funds) to add 34.5 new positions at DSS to form the Governor’s budget uses the rates currently a CCR implementation team to, among other paid to RCL 14 group homes and ITFC providers responsibilities, oversee policy development as well as placeholder figures for the new provider rates as a robust stakeholder workgroup process. under CCR. For 2016-17, DHCS requests $175,000 General Summary of Governor’s Estimated Costs and Fund ($350,000 total funds) to help STRTCs Savings for 2016-17 CCR County Implementation. obtain mental health certification. Across the Figure 12 shows the Governor’s estimated costs and state there are over 700 group homes, a subset of assumed county foster care payment savings for which will likely seek mental health certification as the major components of the 2016-17 CCR budget they convert to STRTCs. If an STRTC chooses to Figure 12 Proposed CCR State Spending for County Child Welfare and Probation Department Implementation (In Millions) 2015-16 2016-17 Change From 2015-16 General Total General Total General Total Activity Fund Funds Fund Funds Fund Funds Foster parent training, recruitment, retention, and $17.2 $25.8 $32.2 $47.4 $15.0 $21.6 support Resource Family Approvala — — 11.2 16.2 11.2 16.2 Child and family teaming — — 9.7 14.4 9.7 14.4 2015-16 FFA rate increase 4.3 7.3 4.5 7.6 0.2 0.3 Case planning assessment, reviews, and training — — 4.4 6.6 4.4 6.6 Accreditation — — 1.4 2.8 1.4 2.8 Automation and performance measure development — — 0.5 0.8 0.5 0.8 Assumed foster care payment savings at the — — -6.4 -7.3 -6.4 -7.3 county levelb Totalsc $21.5 $33.1 $57.5 $88.6 $36.0 $55.5 a Estimated total spending for Resource Family Approval is net of estimated county savings, which are estimated at approximately $19 million in total funds. b Assumed foster care payment savings offset the costs of the other proposed CCR activities, reducing the total estimated state funding for CCR implementation. c This figure does not include the approximately $3.4 million General Fund ($6.4 million total funds) in the Governor’s proposed budget to support DSS state operations, DHCS state operations, and county Mental Health Plans’ CCR implementation efforts. CCR = Continuum of Care Reform; FFA = Foster Family Agency; DSS = Department of Social Services; and DHCS = Department of Health Care Services. 30 Legislative Analyst’s Office www.lao.ca.gov 2016-17 BUDGET provide the services directly, CCR requires that it uncertainties surrounding the total fiscal impact obtain certification from DHCS or a county MHP. and programmatic challenges of the reform DHCS requests additional resources to support one package remain. The Governor’s budget recognizes permanent position and temporary funding for that implementation will result in up-front costs two positions to directly certify the new STRTCs for the counties. Offsetting those costs are assumed and assist county MHPs that choose to carry out county savings that are projected to materialize STRTC certification themselves. beginning in 2016-17. These offsetting savings are uncertain because they are based upon particular LAO Assessment assumptions about rates (which have not been finalized) and other assumptions about the number Governor’s Proposal Is a Logical Next and speed at which children will exit group Step for CCR Implementation homes (which will depend upon the availability Full implementation of AB 403 is expected of home-based family caregivers). Ultimately, the to be a multiyear effort. Funding for CCR future costs or savings from CCR are contingent implementation began in 2015-16 with an on a host of interconnected factors, including the augmentation for counties to increase outreach, new STRTC and FFA foster care payment rates recruitment, and support for foster parents that DSS develops, the rate at which children and to provide an increase to the FFA rate. exit group homes to home-based family care, The Governor’s 2016-17 proposal builds upon and which home-based family settings are most the 2015-16 efforts, and continues to primarily heavily utilized following the closure of group focus early implementation efforts on building homes. Programmatically, the ability of counties to capacity in home-based family settings while recruit and support additional home-based family beginning to phase in other components of CCR caregivers will be critical to CCR’s success. implementation. We have reviewed the Governor’s Availability of New Home-Based Family proposal for new positions at DSS and DHCS. Placements Key to CCR’s Success. Currently, over Given the magnitude of the CCR implementation 5,500 children reside in group homes. DSS projects efforts, we find them to be reasonable. We note that around 2,500 of these children will gradually that the request for DSS positions includes limited transition to home-based family placements term funding, which will allow the Legislature over the three years following implementation. to reevaluate the ongoing CCR workload when Child welfare and probation departments are implementation is further along. Overall, we find developing strategies to better identify and that the Governor’s proposal is a logical next step support home-based family settings for children in the implementation of CCR, but recognize that transitioning from group homes. many uncertainties continue to surround CCR Recognizing the necessity of finding new implementation. We highlight several of these key home-based family caregivers under AB 403, uncertainties in this section. the Governor dedicates nearly half of new CCR spending to counties for foster parent recruitment Considerable Fiscal and Programmatic and retention. County welfare and probation Uncertainties Surround CCR Implementation departments’ ability to translate these funds Because CCR results in a fundamental shift into additional home-based family caregivers is in the way CWS are delivered in California, large unknown at this time. As we have noted, AB 403 www.lao.ca.gov Legislative Analyst’s Office 31 2016-17 BUDGET requires DSS to report at upcoming legislative CCR’s Net Costs Will Ultimately Depend on hearings on the recruitment and retention efforts Speed of Transition and Finalization of Rates. currently underway. Without a considerable increase The level at which the state sets rates will help in the number of home-based family placements, determine CCR’s fiscal impact. Higher rates for CCR’s goal of reducing the state’s reliance on children in STRTCs and FFAs than what the long-term group home placements cannot be met. Governor’s budget assumes will erode potential The Speed at Which Children Will Leave savings accruing from transitioning children out Group Homes Is Unknown. In estimating 2016-17 of group homes, even more so if that transition is savings for counties, DSS assumes a steady slower or less complete than anticipated. transition of children out of group homes and As we have noted, the administration’s into STRTCs or home-based family placements. estimates of foster care payment savings assumes What the exit rate will ultimately be is subject that the rates paid to FFAs and STRTCs will be to significant uncertainty, such as the extent to roughly similar to those in place today. While which group homes successfully petition for we recognize that this approach is prudent in license extensions past CCR’s January 1, 2017 the absence of new, finalized rates, using current implementation date. By January 2019, all child rates could underestimate the future costs of welfare group home placements must cease, but STRTC and FFA provider payments, potentially probation group home placements may potentially underestimating total General Fund costs for continue indefinitely. In both the short and long CCR implementation. The administration will be run, children remaining in group homes will add releasing the rate structure in March, at which time cost pressures to CCR that may affect its net fiscal it should have a better estimate of potential costs impact. and savings. New Rate Structures for FFAs and STRTCs Realignment May Complicate Budgeting Are Still Under Development. The new rate for CCR Implementation. As we have noted, structures currently under development will take under 2011 realignment, if the state places new into account the new requirements of CCR— requirements on counties, it must provide state accreditation, mental health certification, CFT, resources to reimburse counties for the new and the augmented slate of core services that FFAs costs. Counties are not required to implement and STRTCs must provide. The near finalization any changes in state policy that increase overall of regulations surrounding new core service program costs unless the state provides funding to requirements is a precondition to the final adoption cover those increased costs. The Governor’s budget of a rate system since the payments providers attempts to compensate counties for the increased receive must take into account the services they net costs associated with CCR, but as we have will be required to provide. Moreover, as previously noted, current estimates are based on a number of noted, alternative rate models may be considered assumptions. We think it is reasonable to assume that would tie, at least in part, the rate a child’s counties could realize some level of savings as caregiver and service provider receive to the child’s children transition out of group homes and that needs assessment rather than the child’s placement these savings could be used to offset the state’s cost type. Which model is ultimately adopted will likely for CCR. However, the net impact on counties will have important programmatic and fiscal effects, ultimately depend upon the finalization of rates which are unknown at this time. and the speed at which children transition from 32 Legislative Analyst’s Office www.lao.ca.gov 2016-17 BUDGET more costly care. Adding to the uncertainties, there These suggestions are primarily focused on may be wide variation in the speed and level of gaining additional clarity around the key issues of savings achieved across the various counties. uncertainty we raise in this analysis. Uncertainties Surrounding Mental Health CCR Implementation Costs and Savings Services and Certification. Assembly Bill 403 Subject to Change Once New Rates Are Finalized. requires that all STRTCs and FFAs either obtain The long-term cost of CCR largely depends on mental health certification from DHCS or county the savings achieved from children exiting group MHPs or contract with a certified mental health home care. Due to the absence of finalized rates provider. For FFAs and STRTCs, there is some in the Governor’s January budget, the likelihood uncertainty around what certification will require and extent of county savings from lower foster care and who will be the certifying entity or entities. It payments is uncertain. The Legislature will want to is our understanding that counties have concerns revisit the proposed CCR implementation funding that insufficient resources are being provided for once new provider rates are developed in March, at MHPs to prepare for the influx of new applicants which time more accurate savings and costs can be and potential service recipients should the plans estimated. have a direct role in certifying providers and Use Budget Deliberations to Gain Clarity on administering services to these additional children. Key Aspects of the Proposal. As we have noted, The Governor proposes funding for DHCS and there are several other components of CCR that MHPs to carry out CCR-related workload, but the create some uncertainty. The Legislature may wish augmentation is limited to what is needed to serve to use the upcoming budget process to ask the STRTCs. FFAs facing the same rules as STRTCs do administration some clarifying questions around not appear to be accounted for in the Governor’s these areas of uncertainty. The following are some mental health-related budget augmentations. It is key issues for the Legislature’s consideration: unclear whether there may be additional General • Addressing Realignment Challenges. Fund cost pressures associated with the mental Given the uncertainty surrounding health certification of FFAs. DSS is convening a CCR’s net costs or savings, how will the workgroup with DHCS and representatives from administration ensure that it is accurately the county MHPs to focus on the role of mental funding counties for the newly required health in CCR. Additionally, the administration activities under CCR? How will the is considering legislation that will provide more administration track county savings clarity on the mental health component of CCR. attributable to CCR on an ongoing basis? Key Issues for Legislative Consideration • How Core Services Will Be Made Overall, we find the Governor’s proposal Available to All Children. Once the rates to continue the implementation of CCR to be a are developed, the Legislature may want reasonable next step. We also find the Governor’s to ask the administration to provide request for additional positions at DSS and greater detail to demonstrate if and how DHCS to oversee and implement CCR to be the new rate structure increases access to reasonable and raise no concerns at this time. core services for all children regardless of We do, however, make some suggestions for the placement setting. Legislature to consider as it evaluates the proposal. www.lao.ca.gov Legislative Analyst’s Office 33 2016-17 BUDGET • Recruitment and Retention Funding. The upcoming budget process, such as the ability to recruit and retain home-based number of home-based families recruited family placements is important to the and key recruitment and retention success of CCR. Under current law, the challenges counties are experiencing. administration is required to report in • Role of Mental Health. Based on progress budget hearings on counties’ uses of these from the mental health workgroup process, funds, providing an opportunity for and deliberations on potential legislation the Legislature to oversee the strategies, to clarify the role of mental health in CCR, allocation amounts, and progress of the what is the most up-to-date vision of how funding. Given the increased funding for mental health will be further integrated this effort, the Legislature may consider with CWS under CCR? requiring the department to include other oversight measures in this report in the 34 Legislative Analyst’s Office www.lao.ca.gov 2016-17 BUDGET www.lao.ca.gov Legislative Analyst’s Office 35 2016-17 BUDGET Contact Information Ginni Bella Navarre Managing Principal Analyst, 319-8342 Ginni.Bella@lao.ca.gov Health and Human Services Callie Freitag SSI/SSP 319-8331 Callie.Freitag@lao.ca.gov In-Home Supportive Services Ben Johnson Child Welfare Services 319-8336 Ben.Johnson@lao.ca.gov Continuum of Care Reform Ryan Woolsey CalWORKs 319-8356 Ryan.Woolsey@lao.ca.gov LAO Publications The Legislative Analyst’s Office (LAO) is a nonpartisan office that provides fiscal and policy information and advice to the Legislature. To request publications call (916) 445-4656. This report and others, as well as an e-mail subscription service, are available on the LAO’s website at www.lao.ca.gov. The LAO is located at 925 L Street, Suite 1000, Sacramento, CA 95814. 36 Legislative Analyst’s Office www.lao.ca.gov