Child Welfare Placement Continuum

Federal Financing for Congregate Care Placements

Family First changed federal funding for placement reimbursement. Placement in Residential Child Care Facilities, group homes, and group centers are no longer eligible for federal reimbursement beyond 14 days, unless they are licensed and accredited as Qualified Residential Treatment Programs (QRTPs) or serve designated “carve-out” populations. This CDHS Operation Memo (OM-CW-2021-0015) offers further guidance about processes to operationalize congregate care provisions of the law.

Specialized Settings

Family First allows for federal reimbursement of specific congregate care settings for certain populations, sometimes called “carve-out populations:” These specialized group settings include programs for youth at risk of or survivors of trafficking; prenatal or parenting youth; and youth 18 years of age or older living independently with supervision. This CDHS Operation Memo (OM-CW-2021-0016) offers further guidance about the standards for operating programs that provide specialized services to pregnant and/or parenting children/youth, children/youth who are survivors of sex trafficking or children/youth who are at risk of being trafficked. New rules for specialized settings have not yet been approved by the State Board.

Supporting Kin

Family First further supports increased utilization of kinship families and reimburses for some Kinship Navigator Program services. We know that permanent or temporary placements with kin help maintain familial relationships and cultural connections, support parent reunification efforts, and often prevent further trauma and result in better outcomes for children and youth when they aren’t able to remain safely in the home.

Additional information on efforts to support kinship caregivers:

• Foster Source is a nonprofit organization offering trauma education, relief services and therapeutic services to foster and kinship families throughout Colorado. They are also working on a database called “Respite Source” to connect families with respite options.
• CHAMPS Colorado strives to ensure vulnerable kids are safe and thriving by promoting foster and kin families as a vital component of the child welfare system. They launched in May 2020 in partnership with Foster Source and are part of a national campaign to ensure quality parenting for all children in foster care. CHAMPS is engaging with CDHS to provide a foster and kin family voice in the implementation of child welfare policies. On the county level, CHAMPS is working in several pilot counties to improve programs for foster and kin families to ultimately increase retention rates.
• The Kinship Foster Taskforce has been established to discuss changes to statute and rule to reduce barriers for kin to become certified foster care providers and establish practices that better support kinship care.
• Colorado’s Juvenile Justice Reform Bill (SB19-108) requires identification of kin for supports and placement purposes. In delinquency court cases, support is allowed for kinship providers.

Family-Like Placements in the Community

Colorado needs foster families that can effectively serve higher acuity children and youth, who historically have been placed in congregate care settings. While treatment foster care currently exists in a very limited capacity in the state, therapeutic foster care is a new level of care in Colorado. Effective July 1, 2021, new rates have been developed for Treatment Foster Care and Therapeutic Foster Care placements (IM-CW-2021-0035). Child maintenance rates were also updated effective July 1, 2021 and include respite and foster parents support costs. The Foster Care Placement Continuum Task Group is examining historical barriers contributing to the lack of treatment foster homes and creating a recruitment strategy for therapeutic foster homes. CDHS has developed a set of key strategies, based on stakeholder input, for rightsizing and refining the placement continuum.

Qualified Residential Treatment Programs (QRTPs)

Family First created a new short-term, high-quality, treatment-centered level of care called Qualified Residential Treatment Programs (QRTPs). QRTPs can be used for placement only when a child’s or youth’s behavioral health treatment needs cannot be met with any other lower level of care. QRTPs must have a trauma-informed treatment model, have registered or licensed nursing and other clinical staff available 24/7, be licensed by the state, and be nationally accredited. QRTPs should NOT be used for containment purposes or due to a lack of other placement options. To place a child or youth in a QRTP, the county child welfare agency must request an independent assessment by a qualified individual before or upon admission to a QRTP.
HCPF Policy for Residential Providers

The Department of Health Care Policy & Financing (HCPF) has updated their draft policy regarding child- and youth-serving residential treatment facilities. The only provider types that will be reimbursed by Medicaid after June 30, 2022, when HCPF’s residential policy is fully implemented, are QRTPs and PRTFs. The two exceptions to this policy are: CHRP providers and SUD providers. This policy addresses the Institution for Mental Disease (IMD) considerations under Medicaid so the state can move forward with residential facilities in alignment with Medicaid and new Title IV-E provisions of Family First. The new policy outlines that Medicaid reimbursement will be available for medically necessary stays in treatment facilities of 16 beds or fewer and provides further guidance on the transition for providers. This policy will go into effect no later than Oct 1, 2021 in order to allow QRTPs to enroll in Medicaid as a new provider type as required by Family First. However, there is an extended transition period up to June 30, 2022 for remaining providers/facilities to meet the guidelines of this policy. All facilities enrolling in Medicaid must complete HCPF’s attestation form to demonstrate compliance with the new policy.

Psychiatric Residential Treatment Facilities (PRTFs)

Beyond QRTP level of care, are there other options for a higher level of care? A Psychiatric Residential Treatment Facility (PRTF) is a higher level of care than a QRTP and operates primarily from a medical approach for higher acuity mental health conditions that may require stabilization efforts, medication management, and care for physical risk factors (i.e. self-harm, aggression, etc.). It is a non-hospital facility with a provider agreement with a State Medicaid Agency to provide the inpatient services benefit to Medicaid-eligible individuals under the age of 21. CDHS has created a reference guide that details differences between RCCF-QRTP, RCCF Non-QRTP, and PRTF levels of care. There is a long version of the resource and an executive summary version available. In addition, HCPF created a draft PRTF Q&A factsheet which attempts to answer some of the policy, process, and financing questions to accessing and utilizing this level of care. Funding ($13.7M in FY 2022-23) for Medicaid services (PRTF placements) is included in the Block allocation to counties and goes through the county block allocation in CFMS. Services are entered in Trails as a “no pay” to counties. Questions around and barriers to accessing this level of care in Colorado started surfacing in 2021 when talking about the placement continuum. In early 2021 there were only two active PRTFs in the state of Colorado, which were primarily serving out of state residents. Effective July 1, 2021 the PRTF rate was increased to $750 per day (HCPF Provider Bulletin). View the facilities that are currently pursuing or already have a PRTF license.

Family First Transition funding

SB21-278 required that CDHS assist residential placement providers in transitioning to models that are Title IV-E and medicaid eligible with Colorado Transition Act funding. About $1.1 million of the state’s transition funds were awarded in grants to providers. A separate solicitation for efforts focused on building a comprehensive continuum of placement options across the state was awarded in 2021. The opportunity included efforts to serve high acuity youth in family-like settings; recruitment and retention of therapeutic and treatment foster homes; enhanced supports for foster parents and kinship families; and efforts to better understand and respond to the needs of Colorado’s children and youth in all types of care. More details about awardees can be viewed on this page.

Funding Options for Residential Treatment

This flowchart created by the Colorado Department of Human Services provides county child welfare agencies guidance regarding obtaining funding and approval for residential treatment for children and youth.
Independent Assessment Process for QRTP Placement
See Independent Assessment Process for QRTP Placement