The 2021-22 Budget: Analysis of Child Welfare Proposals

analysis full gutter The 2021-22 Budget: Analysis of Child Welfare Proposals FEBRUARY 2021 California’s children and family programs are not responsible or only partially responsible include an array of services to protect children for CWS programmatic cost increases resulting from abuse and neglect and to keep families safely from federal, state, and judicial policy changes. together when possible. This analysis: (1) provides Proposition 30 establishes that counties only need program background; (2) outlines the Governor’s to implement new state policies that increase overall proposed budget for children and family programs, program costs to the extent that the state provides including child welfare services (CWS) and foster the funding. Counties are responsible, however, care programs, in 2021-22; and (3) provides key for all other increases in CWS costs—for example, questions and issues for the Legislature to consider those associated with rising caseloads. Conversely, as it evaluates the budget proposal. if overall CWS costs fall, counties retain those savings. Program Background Continuum of Care Reform (CCR). Beginning CWS. When children experience abuse or in 2012, the Legislature passed a series of neglect, the state provides a variety of services to legislation implementing CCR. This legislative protect children and strengthen families. The state package makes fundamental changes to the provides prevention services—such as substance way the state cares for youth in the foster care use disorder treatment and in-home parenting system. Namely, CCR aims to: (1) end long-term support—to families at risk of child removal, to congregate care placements; (2) increase reliance help families remain together if possible. When on home-based family placements; (3) improve children cannot remain safely in their homes, the access to supportive services regardless of the kind state provides temporary out-of-home placements of foster care placement a child is in; and (4) utilize through the foster care system, often while providing universal child and family assessments to improve services to parents with the aim of safely reunifying placement, service, and payment rate decisions. children with their families. If children are unable to Under 2011 realignment, the state pays for the net return to their parents, the state provides assistance costs of CCR, which include upfront implementation to establish a permanent placement for children, costs. While not a primary goal, the Legislature for example, through adoption or guardianship. enacted CCR with the expectation that reforms California’s counties carry out children and family eventually would lead to overall savings to the foster program activities for the state, with funding from care system, resulting in CCR ultimately becoming the federal and state governments, along with local cost neutral to the state. We note that CCR is a funds. multiyear effort—with implementation of the various 2011 Realignment. Until 2011-12, the state components of the reform package beginning at General Fund and counties shared significant different times over several years—and the state portions of the nonfederal costs of administering continues to work toward full implementation in the CWS. In 2011, the state enacted legislation known current year. For more detailed background on CCR as 2011 realignment, which dedicated a portion of and its various components, refer to our previous the state’s sales and use tax and vehicle license fee CCR budget update here. revenues to counties to administer child welfare and Extended Foster Care (EFC). At around the foster care programs. As a result of Proposition 30 same time as 2011 realignment, the state also (2012), under 2011 realignment, counties either implemented the California Fostering Connections 2021-22 LAO Budget Series 1 analysis full gutter to Success Act (Chapter 559 of 2010 [AB 12, Beall]), (SILPs) or transitional housing placements. which extended foster care services and supports to SILPs are independent settings, such as youth from age 18 up to age 21, beginning in 2012. apartments or shared residences, where NMDs To be eligible, a youth must have a foster care order may live independently and continue to receive in effect on their 18th birthday, must opt in to receive monthly foster care payments. Transitional EFC benefits, and must meet certain criteria (such housing placements provide foster youth as pursuing higher education or work training) while ages 16 to 21 supervised housing as well as in EFC. Youth participating in EFC are known as supportive services, such as counseling and non-minor dependents (NMDs). In addition to case employment services, that are designed to management services, NMDs receive support for help foster youth achieve independence. independent or transitional housing. Total Foster Care Placements Have Remained Foster Placement Types. As described above, Stable, With Shifts in Placement Types. Over the when children cannot remain safely in their homes, past decade, the number of youth in foster care they may be removed and placed into foster care. has remained around 60,000 (ranging from around Counties rely on various placement types for foster 55,000 to around 63,000 at any point in time). youth. Pursuant to CCR, a Child and Family Team While the total number of placements has remained (CFT) provides input to help determine the most stable, the predominance of various placement appropriate placement for each youth, based on types has shifted over time. In particular, pursuant to the youth’s socio-emotional, behavioral and mental the goals of CCR, congregate care placements have health needs, and other criteria. Placement types decreased, while more independent placements include: have increased since the implementation of EFC. • Placements With Resource Families. For Figure 1 on the next page illustrates changes in most foster youth, the preferred placement foster placements over time. type is in a home with a resource family. Federal Family First Prevention Services A resource family may be kin (either a Act (FFPSA). Historically, one of the main federal non-custodial parent or relative), a foster family funding streams available for foster care—Title approved by the county, or a foster family IV-E—has not been available for states to use on approved by a private foster family agency services that may prevent foster care placement in (FFA). FFA-approved foster families receive the first place. Instead, the use of Title IV-E funds additional supports through the FFA and has been restricted to support youth and families therefore may care for youth with higher-level only after a youth has been placed in foster care. physical, mental, or behavioral health needs. Passed as part of the 2018 Bipartisan Budget Act, • Congregate Care Placements. Foster youth FFPSA expands allowable uses of federal Title with intensive behavioral or mental health IV-E funds to include services to help parents and needs preventing them from being placed families from entering (or re-entering) the foster care safely or stably with a resource family may be system. Specifically, FFPSA allows states to claim placed in a Short-Term Residential Therapeutic Title IV-E funds for mental health and substance Program (STRTP). These facilities provide abuse prevention and treatment services, in-home specialty mental and behavioral health services parent skill-based programs, and kinship navigator and 24-hour supervision. STRTP placements services once states meet certain conditions. are designed to be short term, with the goal FFPSA additionally makes other changes to policy of providing the needed care and services to and practice to ensure the appropriateness of all safely transition youth to resource families. congregate care placements, reduce long-term congregate care stays, and facilitate stable • Independent and Transitional Placements transitions to home-based placements. for Older Youth. Older, relatively more self-sufficient youth and NMDs may be placed The law is divided into several parts; Part I (which in supervised independent living placements is optional and related to prevention services) and 2021-22 LAO Budget Series 2 analysis full gutter Figure 1 Foster Care Placements: Point-in-Time Counts 2010 to 2020 Number of Youth in Foster Care Other Congregate care placements Independent and transitional Placements with resource families placements for older youth 65,000 55,000 45,000 35,000 Change From 2010 to 2020 10% 8 25,000 6 4 2 Independent 15,000 -2 and transitional -4 Congregate placements Other care for older youth -6 Placements with resource families 5,000 2010 2012 2014 2016 2018 2020 Data from California Child Welfare Indicators Project (CCWIP). Retrieved January 29, 2021 from University of Califoria Berkeley CCWIP website. Data reflects point-in-time count of youth in care for October 1 of each year shown. Data reflects child welfare placements; probation placements not included. Other placement types include pre-adoption placements and trial home visits, guardian placements, youth in shelters, youth who have runaway or are missing, and other placements. 2021-22 LAO Budget Series 3 analysis full gutter Part IV (which is required and related to congregate funds are budgeted for all of 2020-21 but only care placements) have the most significant impacts part of 2021-22. for California. States are required to implement • Expiration of Federal Supplemental Title Part IV by October 1, 2021 in order to prevent the IV-B Funds. Also in response to the pandemic, loss of federal funds for congregate care. States the federal government provided one-time may not implement Part I until they come into supplemental federal Title IV-B funds through compliance with Part IV. the Coronavirus Aid, Relief, and Economic Security Act. This funding for eligible CWS may Overview of Governor’s Budget be expended through September 2021. Total Funding for Child Welfare Services • Ramp Down of Federal Family First and Foster Care Increases, While State and Transition Act Funding. The federal Family Federal Shares Decrease Slightly. As illustrated First Transition Act supports counties in by Figure 2, the 2021-22 Governor’s Budget their transition to FFPSA. For counties that proposal estimates total spending for child welfare previously participated in Title IV-E Waiver programs would increase by around $264 million Demonstration Projects (which ended in from 2020-21 to 2021-22. This net change includes September 2019), funding certainty grants— decreases in federal and state General Fund based on funding provided to counties spending, offset by increases in county spending through the waiver projects in federal fiscal and Title XIX reimbursement for health-related year 2019—are provided in federal fiscal years activities. 2020 and 2021. Maximum grant amounts Primary drivers of the federal and state funding decrease from 90 percent of base year funding decreases include: in 2020 to 75 percent of base year funding in 2021. In addition, the federal government • Expiration of Temporary Federal Medical provided one-time grant funding in 2020 to Assistance Percentage (FMAP) Increase. help all counties begin to implement FFPSA. In response to the pandemic, the federal • Ramp Down of Some State Pandemic government is providing a temporary Response Efforts. Some one-time and 6.2 percent increase to FMAP for eligible limited-term state expenditures for pandemic Title IV-E foster care, adoptions assistance, response are projected to end in 2020-21, and kinship guardian cases. The Governor’s while others are projected to end midway budget assumes the temporary FMAP increase through 2021-22. We discuss pandemic ends midyear 2021-22, meaning increased Figure 2 Proposed Local Assistance for Child Welfare and Foster Care Includes Child Welfare Services, Foster Care, AAP, KinGAP, and CalWORKS ARC (In Millions) State Total Funds Federal Funds General Fund County Funds Reimbursement 2020-21 revised budget $7,083 $3,260 $845 $2,799 $179 2021-22 Governor’s Budget proposal 7,347 3,251 797 3,110 189 Change $264 -$9 -$48 $311 $10 Notes: DSS made display adjustments to county funds to reflect more holistic expenditures, including growth to the LRF subaccounts. The display adjustments include partial changes in 2020-21 and full-year changes in 2021-22. This resulted in what appears to be a year-over change for county funds of more than $1.5 billion. For future years, DSS’ display will include LRF adjustments, and we will update our numbers accordingly. For this table, however, we have removed the display changes to ensure year-over changes in county and total funds do not appear overly large. AAP = Adoption Assistance Program; KinGAP = Kinship Guardianship Assistance Payment; ARC = Approved Relative Caregiver; DSS= Department of Social Services; and LRF = Local Revenue Fund. 2021-22 LAO Budget Series 4 analysis full gutter response for child welfare programs in more with the administration to better understand detail later in this post. what portion of the HBFC rate increase is • Decrease in State Funding for Placement due to LOC assumptions. We provide more Prior to Approval for Emergency detail about the LOC protocol tool and its Caregivers. When children are removed from implementation in our previous child welfare their homes, certain individuals (primarily budget analysis here. relatives) are eligible to begin providing foster • Slight Increase in Funding for Other CCR care without prior approval as a resource Expenditures. The Governor continues to family. Current statute dictates these eligible propose the state provide funding for counties individuals may receive foster payments for up to implement some elements of CCR. Aside to 120 days (or up to 365 days if a good-cause from funding for HBFC rates and placement extension is warranted) while completing the prior to approval for emergency caregivers— resource family approval process. In 2021-22, both of which are described above—other the statutory time limit for pre-approval funding CCR expenditures include: CFTs, Resource decreases to 90 days, without any option for Family Approval (RFA), LOC protocol tool, extension. Statewide Automated Welfare System project, • Expiration of One-time State Funds for second level administration review, contracts, Counties in 2020-21. The state provided a and CCR reconciliation. We provide more one-time payment of $80 million to counties in detail about these elements of CCR in our 2020-21 for CWS. We understand these funds previous child welfare budget analysis here. were intended to reimburse counties for some Funding for most of these CCR elements is CCR-related implementation costs. unchanged year over year, while funding for CFTs increases by a few million dollars in The state and federal funding reductions 2021-22, reflecting more up-to-date caseload described above are partially offset by some notable estimates. increases in federal and state child welfare spending • FFPSA Part IV Implementation. The in 2021-22: administration’s 2021-22 budget proposal • State and Federal Increases for includes funding for several new activities Home-Based Family Care (HBFC) Rates. related to implementing Part IV of FFPSA. We Pursuant to CCR, foster care payments are describe the administration’s FFPSA proposal shifting from the prior age-based rate system in more detail later in this post. to universal HBFC rates for resource families. • Other Changes, Including Federal Increases Resource families caring for youth with a for Realigned Programs. Other changes higher level of need—as assessed through in estimated expenditures from 2020-21 to a Level of Care (LOC) protocol tool—receive 2021-22 reflect expected annual growth of higher monthly foster care payment rates. realigned programs, such as for foster care In 2021-22, HBFC rates receive a statutory assistance payments ($30 million federal cost-of-living adjustment (COLA). Additionally, increase), adoption assistance program we understand that the administration’s payments ($16 million federal increase), county estimate assumes the LOC protocol tool is administration of foster care ($31 million fully rolled out in 2021-22. To date, however, federal increase), and CWS program costs the tool has been rolled out only to FFA ($118 million federal increase). These changes placements and there is no clear time line for reflect updated expenditure data, COLAs, and roll out to county-approved resource family projected caseload growth. placements at this time. We are working 2021-22 LAO Budget Series 5 analysis full gutter Figure 3 summarizes all of the federal and state funding amounts listed in the figure reflect new funding changes described above. proposals from the administration as part of the 2020-21 revised budget at the time of the 2021-22 • County Expenditures Increase Primarily Governor’s Budget proposal. The administration Due to Growth in Realigned Programs. The has indicated the proposed activities would begin estimated increase in county expenditures in January 2021. Therefore, we note that there from 2020-21 to 2021-22 reflects the appears to be a funding gap between July 2020 and administration’s projections based on historical January 2021. We are currently working with the expenditure trends for realigned programs, administration to better understand what actions including foster care assistance payments and (if any) counties have been able to take to continue administration, adoption assistance program these pandemic supports in the interim, and payments and administration, and CWS what authority and communication is needed for program costs. Additionally, the estimated counties to continue (or re-launch) these supports increase in county expenditures includes the for youth and families in 2020-21. At this point, the administration’s assumptions about the county administration has not provided any details as to share of costs to implement FFPSA Part IV how these proposals would be authorized in the ($37 million). current year. Pandemic Response Would Continue. In the Implementation of FFPSA Part IV Would weeks following the state and federal emergency Begin. As noted earlier, states are required to come declarations in response to coronavirus disease into compliance with the congregate care provisions 2019, the state authorized funding in 2019-20 for stipulated by Part IV of FFPSA by October 1, 2021. several measures to provide pandemic support to If not in compliance by that time, states will lose families within the child welfare system. Figure 4 at federal funding for congregate care placements. the top of the next page summarizes these actions As part of ongoing CCR, California already has in addition to new action the administration has made changes to congregate care that position proposed as part of its 2021-22 budget proposal. the state ahead of many others in terms of coming We note that 2019-20 funding ended into compliance with FFPSA Part IV. Namely, June 30, 2020. For all 2020-21 actions other California has made significant progress toward than flexibilities and expansions for NMDs, reducing reliance on congregate care, instead Figure 3 Summary of Changes in Child Welfare Spending (In Millions) 2020-21 revised 2021-22 Governor’s Budget Change Federal State Federal State Federal State Funds General Fund Funds General Fund Funds General Fund Temporary FMAP increase $139 — $70 — -$68 — Supplemental Title IV-B funds 5 — — — -5 — Family First Transition Act 295 — 129 — -166 — State pandemic response — $85 — $61 — -$24 Placement Prior to Approval 10 32 5 15 -6 -17 One-time state funds to counties — 80 — — — -80 HBFC rates 103 211 111 227 8 17 Other CCR expenditures 29 76 30 81 1 4 FFPSA Part IV implementation — — 18 43 18 43 Other changes — — — — 208 9 Totals -$9 -$48 FMAP = federal medical assistance percentage; HBFC = home-based family care; CCR = Continuum of Care Reform; and FFPSA = Family First Prevention Services Act. 2021-22 LAO Budget Series 6 analysis full gutter Figure 4 State Funds for Pandemic Response Within Child Welfare Programs (In Thousands) 2019-20a 2020-21b 2021-22c Cash cards for families at risk of foster care $27,842 $28,000 — Family Resource Centers funding 3,468 7,000 $6,000 State contracts for technology (laptops and cell phones) and hotlines for foster youth and familiesd — 2,042 1,750 Administrative workload for child welfare social workers (overtime and pandemic outreach) 5,000 — — Rate flexibilities for resource families directly impacted by pandemic 3,005 9,136e 3,458 Flexibilities and expansions for NMDs/former NMDs who turn 21 or lose otherwise lose eligibility for 1,846 37,133 49,487 EFC due to pandemic Pre-approval funding for emergency caregivers beyond 365 days 1,312 1,234 — Totals $42,473 $84,545 $60,695 a For 2019-20, funds were provided April through June 2020. Activities were approved by the Legislature through the Section 36.00 letter process. b For 2020-21, pandemic-response activities are proposed by the administration for January through June 2021 for all actions other than flexibilities and expansions for NMDs. The Legislature has not yet approved these activities for 2020-21, with the exception of flexibilities and expansions for NMDs, which were included in the 2020-21 Budget Act and are in place July 1, 2020 through June 30, 2021. c For 2021-22, funds are proposed by the administration for July through December 2021. d Funding for state contracts for technology and hotlines in 2019-20 is included in the amount for Family Resource Centers funding. e Includes $5.678 million funding from DREOA. Note: Where applicable, amounts include assistance plus administration costs. NMD = non-minor dependents; EFC = extended foster care; and DREOA = Disaster Response Emergency Operations Account. providing more supports and services to youth in • QI Assessment of Congregate Care resource family placements and more independent Placements. FFPSA requires a qualified living placements, and providing intensive services individual (QI), who is medically certified, to through STRTPs when a youth cannot safely be assess and report on the appropriateness of all placed in a resource family home. As such, CCR STRTP placements. The administration’s plan efforts run parallel to the goals of FFPSA Part IV’s includes funding for QIs to participate in CFTs, congregate care reforms, which aim to ensure the conduct the Child and Adolescent Needs and appropriateness of all congregate care placements, Strengths (CANS) assessment, and prepare reduce long-term congregate care stays, and required court documentation for all STRTP facilitate stable transitions to home-based placements. placements. Nonetheless, the state will need to • Access to Aftercare Services. FFPSA make changes to ensure compliance with FFPSA’s requires at least six months of specified congregate care facility licensing standards and support services for youth and families after placement criteria. a youth exits a congregate care placement. To meet FFPSA Part IV requirements, we The administration’s proposal includes funds understand the administration intends to propose to provide aftercare services for at least seven implementing legislation. While the language months for youth transitioning from an STRTP was not yet available at the time of publication, to a family-based care setting. we understand the Governor’s budget proposal • Court-Related Activities. FFPSA requires includes the following elements: enhanced assessment and reporting around congregate care placements. As such, • Guaranteed Access to Nursing Care. FFPSA social workers will need to spend additional requires STRTPs to have 24/7 access to time on court-related activities, such as nursing care. To meet this requirement, the attending additional hearings and completing administration proposes to contract with and supplemental reports for STRTP placements. fund a virtual telehealth hotline, facilitating The administration’s proposal includes funding interaction between STRTPs and nurses at any for these increased social worker costs. time. 2021-22 LAO Budget Series 7 analysis full gutter • Judicial Branch Training. FFPSA requires allowing counties to exercise these flexibilities states to train judges and other court staff on was unclear. We note that General Fund dollars child welfare policies, including federal funding are not included in the Governor’s budget for this limitations for out-of-home foster placements. purpose, meaning if FFPSA Part I implementation The administration proposes to pass Title IV-E legislation were proposed, it likely would be optional funds through to the state’s Judicial Council and counties would need to provide the required for this required training. matching funds using their realignment revenues or • Placement Assessment Evaluation and other county sources to be able to claim additional Review. In California, CFTs use the CANS federal Title IV-E dollars. assessment to determine placements. Proposes Maintaining Program Suspensions To implement FFPSA, the administration Calculation. Under current law, several child proposes that QIs will participate in CFTs welfare programs would be subject to suspension and also will use the CANS tool to assess after December 31, 2021 if the Department the appropriateness of congregate care of Finance found there would not be sufficient placements. The administration proposes to revenues to support them at the time of the establish an ongoing external contract and 2021-22 May Revision. (Under both our office’s funding to evaluate CANS data for placement revenue estimates and those by the Department assessments. of Finance, there would be sufficient revenues to • Various Training. Finally, the administration’s support the programs and the suspension would proposal includes funding for various FFPSA not take effect.) The 2021-22 Governor’s Budget training costs, including training for: QIs proposes to maintain the suspension calculation for on CFTs and CANS procedures, providers the 2021-22 budget. Figure 5 lists the child welfare on developing and implementing aftercare programs on the suspension list. We provide a more services, and social workers on new federal detailed overview of suspensions in our office’s provisions. recent publication on the topic here. FFPSA Part I Option for Counties May Be LAO Comments and Questions for the Included in Proposed Legislation. As we noted Legislature to Consider earlier, once states comply with FFPSA Part IV’s Continued Implementation of CCR: What Is congregate care provisions, Part I affords states the Status of CFTs, CANS, and LOC Protocol the option of using Title IV-E dollars for certain Tool? We are working with the administration to services and activities aimed at preventing entry understand what underlying assumptions it made into foster care. At the time of publication, whether for the 2021-22 budget proposal around continued the administration intends to propose legislation Figure 5 Child Welfare Programs Subject to Suspension General Fund (In Millions) Annual Cost of Program, Program Subject to Suspension Once Fully Implemented Family Urgent Response System $30 Public health nursing early intervention pilot program in Los Angeles County 8 Emergency Child Care Bridge program supplement 10 Foster Family Agency social worker rate increase 7 Transitional Housing Program grants to counties for former foster youtha 8 a Program administered by the California Department of Housing and Community Development. All other programs administered by the Department of Social Services. 2021-22 LAO Budget Series 8 analysis full gutter implementation of certain CCR elements, namely the pandemic response spending in 2020-21 and LOC protocol tool, CFTs, and CANS assessments. 2021-22. We understand that these elements have yet to be In upcoming hearings, the Legislature may fully implemented. If the Governor’s budget proposal wish to ask the administration to provide more assumes full implementation will occur in 2021-22, information about its new proposals for 2020-21. actual expenditures may be lower than budgeted to For example: the extent that there are implementation delays, and • For components that ended June 30, 2020 resulting savings could be directed toward other (or some other date in 2020)—what has legislative priorities. The Legislature may wish to ask been happening since then? Have counties the administration to provide CCR implementation continued exercising flexibilities using local updates during upcoming hearings to better funds? understand any potential savings. For example: • Considering the Legislature has not yet • What is the status of CFT implementation? approved these actions, the funding How many CFTs occurred in 2020? Are mechanism for newly proposed counties on track to achieve universal usage of 2020-21 pandemic response remains CFTs in 2020-21 or 2021-22? unclear. What funding mechanism does the • What is the status of CANS implementation? administration propose to use for newly How many CANS assessments were proposed activities in the current year? completed in 2020? Are counties on track • The administration proposed that counties to achieve universal usage of CANS in could begin activities in January 2021. Did 2020-21 or 2021-22? this occur? What guidance has been provided • What is the status of LOC protocol tool or will be provided to counties to ensure they implementation? Are there plans to roll out the are able to provide the proposed supports in tool beyond FFAs in 2020-21 or 2021-22? 2020-21? Recommend Allowing Extension for Funding Additionally, for pandemic response activities for Emergency Caregivers Prior to RFA. As proposed to continue into the 2021-22 budget we expressed during the previous budget cycle, year, the administration’s proposed funding would we remain concerned that statute dictates end midyear (December 31, 2021). The Legislature funding for pre-approval funding will decrease may wish to ask the administration to provide more to 90 days—without any option for extension— information about: while average RFA processing time continues to • If pandemic resources are needed beyond exceed 90 days. This statutory time limit change December 31, 2021, what action would be will result in emergency caregivers losing access needed to continue supports? Projecting to foster payments if they experience delays in the the course of the pandemic, and predicting RFA process—even when delays are beyond their what needs children and families will have, is control. We recommend the Legislature consider difficult and some continued flexibilities may be changing statute to continue to allow for good needed. cause extension on an ongoing basis, especially during a pandemic. • Regarding support for NMDs and former NMDs, when expansions and flexibilities Questions About Pandemic Response end in December, will youth who become Proposals. As described above, initial state ineligible to remain in EFC be able to transition funding (provided in April 2020) for several successfully? What supports will be provided pandemic response activities within child welfare to help youth prepare for the transition into appears to have ended in June 2020. At the time independence? of the 2021-22 Governor’s Budget proposal, the administration proposed new child welfare 2021-22 LAO Budget Series 9 analysis full gutter Finally, the Legislature may wish to examine these individuals be selected? What would be whether alternative pandemic support proposals the time line for selecting and training QIs? within child welfare should be considered, either in • The administration proposes that QIs addition to or instead of some of the administration’s will participate in CFTs and use CANS proposals. For example, the Legislature could assessments to determine the necessity of consider providing temporary direct support for STRTP placements. If these components resource families and/or STRTPs through monthly of CCR have not been fully rolled out by rate supplements. Such supplemental payments October 1, what alternative processes and could assist caregivers and providers with the higher tools would QIs use? costs of providing foster care during the pandemic Consider Trade-Offs of Allocating State Funds (like for food and utilities), and help mitigate other for FFPSA Part I Implementation. At the time of adverse economic impacts caregivers and providers publication, whether the administration also intends may be facing. For example, providing an additional to propose legislation allowing counties the option $200 for each of the estimated 46,000 foster youth of claiming Title IV-E dollars for newly allowed placed with resource families (including emergency services and activities aimed at preventing entry into caregivers) and in STRTPs would cost around foster care remained unclear. The administration $9.2 million per month. does not include any General Fund dollars for Questions About FFPSA Part IV Proposal. implementation in the 2021-22 Governor’s Budget. As described above, the administration proposes Therefore, if the administration does intend to funds to implement Part IV of FFPSA, as required by introduce FFPSA Part I legislation, we understand October 1, 2021, in order to retain federal funding newly allowed activities would be county options, for congregate care placements. We understand and counties would be able to use local funding for the administration intends to propose legislation these activities at their discretion. Implementing to establish the new program elements and guide FFPSA Part I as a county option without any state their implemention. At the time of publication, this support raises potential equity concerns. Namely, legislation was not yet available. We are currently some counties may not implement optional activities working with the administration to understand due to local budget constraints or differing local additional details and time lines around FFPSA priorities. As a result, families in different counties Part IV implementation. In upcoming hearings, the may receive different levels of service and some Legislature may wish to request additional detail children may not receive the benefits of these from the administration to determine the feasibility programs and therefore could be more likely to enter of meeting the October 1 federal deadline. For foster care. example: To the extent that the Legislature would like to • Are STRTP providers prepared to begin using prioritize prevention activities and ensure families the telehealth hotline, facilitating aftercare at risk of entry into the foster care system benefit services, and meeting other requirements? from new uses of Title IV-E dollars regardless of What training and technical assistance do their county, the Legislature may wish to consider STRTP providers need, and what is the time a General Fund appropriation for counties to begin line? to implement foster care prevention activities under • Are STRTP providers expected to provide FFPSA. Any augmentation would be matched by aftercare services directly, or contract with a federal funds, thereby roughly doubling the fiscal third party to provide the required care? impact, and also potentially could reduce the costs • QIs play an important role in ensuring of foster care over time by preventing entries. To congregate care placements are necessary further explore this issue, the Legislature may wish and meeting new federal reporting to ask the administration: requirements. Who would be QIs? How would 2021-22 LAO Budget Series 10 analysis full gutter • Without state resources, how would the Recommend Rejecting Child Welfare Program administration ensure that all families Suspensions. Our office recently published an throughout the state have access to prevention assessment of the Governor’s overall suspension programs? proposal, which includes a few child welfare • Could the existence of prevention programs in programs, as described in the preceding section some counties and not in others create equity of this post. We recommend the Legislature reject concerns? the Governor’s proposal to create new budget bill suspension language—thereby likely establishing • Could providing funding for prevention the programs on an ongoing basis—but evaluate programs ultimately lead to overall savings to the merits of some of the newer programs’ reporting the child welfare system? and oversight to ensure programmatic design • Has the administration considered creating a aligns with legislative policy objectives and that the loan program or providing one-time start-up programs are resulting in the intended outcomes. funding for counties interested in starting The complete analysis may be accessed on the prevention programs but limited by their own LAO’s website here. fiscal constraints? LAO Publications This report was prepared by Angela Short, and reviewed by Ginni Bella Navarre and Carolyn Chu. The Legislative Analyst’s Office (LAO) is a nonpartisan office that provides fiscal and policy information and advice to the Legislature. 2021-22 LAO Budget Series 11