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Family First
The Family First Prevention Services Act in Colorado: An Implementation Guide for County Directors

Title IV-E Prevention Services

Prior to Family First, federal Title IV-E child welfare funding could only be used if a child or youth was placed outside the home. Family First fundamentally restructures federal child welfare financing streams toward certain evidence-based prevention services aimed at keeping children/youth safely together with their parents/guardians whenever possible. Services can be provided to the child/youth, their parents and/or kin, regardless of the family’s income.

Prevention Services and Programs Eligible for Title IV-E Reimbursement must:

  • Be included in Colorado’s five-year Title IV-E Prevention Program Plan;
  • Provide interventions under a trauma-informed framework;
    Meet certain evidence-based requirements; and
  • Be in one of the following service categories: (1) Mental health services; (2) substance abuse prevention and treatment services; (3) in-home parent skill-based programs; and/or (4) kinship navigator support services.

What County Directors Need to Know

Federal reimbursement for Family First prevention services

Colorado will receive partial federal reimbursement under Family First for delivery of a limited set of approved evidence-based prevention programs and services included in Colorado’s Title IV-E Prevention Program Plan. Colorado’s Plan was approved by our Federal partners in September 2022. The plan has been scaled back significantly to align with the federal requirements around monitoring for safety. Currently, Colorado is only able to claim for delivery of specific services when there’s open child welfare involvement. This DCW memo details Colorado’s phased approach. CDHS will be able to claim on eligible prevention expenditures dating back to October 1, 2021, and deposit drawdown into the Colorado Child Abuse Prevention Trust Fund (HB21-1248). Funding will be awarded via ongoing RFPs to strategically expand evidence-based prevention services over time and build programs in areas of the state where they don’t already exist. More information from the state is available in this state google drive folder.

Colorado’s Family First Prevention Candidacy Definition

For the state to claim federal reimbursement for Family First prevention services when delivered, county child welfare case workers and supervisors must be familiar with Colorado’s Family First Candidacy definition to determine whether a child or youth is a “candidate for prevention services.” In 2020, Colorado’s Prevention Candidacy Definition was submitted for initial review to the federal government as a part of Colorado’s draft state prevention services plan. CDHS is planning to submit an updated plan for official review and approval before October 2021. Colorado’s Prevention Candidacy Definition is in draft version until the federal government approves Colorado’s State Title IV-E Prevention Program Plan.

IV-E Candidacy Determinations

Note that new IV-E Prevention candidacy and traditional IV-E candidacy are separate determinations. Administrative costs can be claimed for two different types of “candidacy” once Family First is implemented: 1) New IV-E reimbursement for administrative and training costs related to preventing entry into foster care for ANY child who is a “candidate for foster care” under the state’s candidacy definition, and 2) Traditional IV-E reimbursement for administrative activities related to pursuing the removal, or providing reasonable efforts to prevent the removal, of a candidate for foster care (conditioned on a child being eligible for Title IV-E foster care). The latter allowable use of Title IV-E Admin will continue to be an allowable use unchanged by Family First. Further details are available in this recorded lunch and learn session, hosted in partnership by CDHS and CHSDA: Session Recording and Powerpoint.

Prevention Continuum

Family First prevention services only represent a part of the continuum of services for strengthening families. There is no requirement that counties must have Family First-specific prevention services available in their communities. Rather, the goal is to ensure all counties have a continuum of high-quality prevention services that meet the needs of families and that over time, Family First-specific services are expanded across all areas of the state in order to increase access to evidence-based prevention services and maximize Colorado’s federal drawdown to reinvest resources back into the continuum. The number of programs and services eligible for Family First federal reimbursement will continue to grow and change over time as more programs meet evidence standards for the Title IV-E Prevention Services Clearinghouse and are added to Colorado’s prevention plan. Read the Colorado Evaluation and Action Lab report on short- and long-term strategy recommendations for implementing and scaling Family First evidence-based prevention programs and services in Colorado..

Expanding capacity looks different for small and medium counties with smaller caseloads in rural and frontier areas. Collaboration across groupings of counties or regionally must be considered. In addition, it will be important for counties, the state, and evidence-based model partners to continue discussions around: hybrid adaptations that incorporate a virtual component and still allow for model fidelity to be met; innovations that allow for some flexibility around minimum qualifications of the workforce as programs are being built. For example, some programs with master’s level staffing requirements are willing to try out starting some staff with bachelor’s, working towards earning their MA through the program.

Funding for Prevention

Counties will continue to use their Child Welfare Block, Core, Collaborative Management Program and other funding sources such as Promoting Safe and Stable Families grants, as well as partner with prevention partners and local providers, to provide a continuum of prevention services that best meet the needs of families in their communities. [see section below “What funding opportunities are available to help build a continuum of prevention programs in your area?”]

Family-Based Residential SUD Facilities

Family First allows for federal maintenance payments for the cost of caring for a child who resides with a parent in a family-based residential facility licensed to provide substance use treatment for adults. The cost of care for adults while in such treatment is often covered through Medicaid, but there has historically been no parallel funding stream to cover the child’s costs of care. Family First addresses this barrier by allowing maintenance payment funding to be used for the child’s costs. Please see more information about the current programs available in Colorado and where they are located [see section below: “Where are the residential substance use disorder treatment programs for parents with children located in Colorado and how do they work?”]

Trauma-informed care requirements

Family First requires that states ensure that, “consistent with the agency’s five-year title IV-E prevention plan, section 471(e)(4)(B) of the Social Security Act requires the title IV-E agency [CDHS] to provide services or programs to or on behalf of a child under an organizational structure and treatment framework that involves understanding, recognizing, and responding to the effects of all types of trauma and in accordance with recognized principles of a trauma-informed approach and trauma-specific interventions to address trauma’s consequences and facilitate healing.” A subcommittee has created a standard for prevention service providers that would help us meet this requirement and work is ongoing. Additional guidance will be provided to counties that contract directly with providers for fulfilling this requirement.

Fidelity Monitoring and Continuous Quality Improvement

Ensuring that CO has a consistent statewide process to monitor fidelity and engaging in the continuous quality improvement requirements of Family First is something that Colorado is currently in the process of figuring out. For some services, there is already an existing tool or metrics used for monitoring fidelity of that service. Then there are other services where that infrastructure doesn’t already exist. Colorado is looking at how we can use some state Transition Funds for a contractor to develop and release a statewide CQI platform and create a process to standardize fidelity metrics across services. Additional guidance will be provided to counties regarding fidelity monitoring and Continuous Quality Improvement (CQI) requirements for providers of Family First prevention services.

Action Items

Ensure child welfare caseworkers and supervisors are prepared for how child welfare practice will look different

Caseworkers should understand the Family First Prevention Services Act and what it means to practice child welfare in their day-to-day work. There is a Family First page on Colorado’s Child Welfare Training System website that offers: a “Technical Assistance for Casework Staff” Q&A resource, a suite of tipsheets and an introductory web-based training.

“Prevention candidacy” determinations are the mechanism through which Colorado can access (drawdown) federal reimbursement to support casework (administrative costs), training costs, and prevention services (direct costs) for children and families when kids can stay at home and/or stay with kin. States in their prevention plan have flexibility to define who is: a “candidate for foster care”/at “imminent risk” of entering foster care and thus, eligible for prevention services under Family First (Colorado’s Family First Candidacy definition). Note that this can include youth involved in the juvenile justice system.

Family First requires specific data to be entered and monitored in Trails in order to collect federal IV-E drawdown for prevention. Case workers complete the determination to identify youth and families who could benefit from federally reimbursable prevention services. In Trails, caseworkers must 1) fill out the IV-E Candidacy Determination Form (Job Aide) to determine whether a child or youth is a “candidate for prevention services,.” 2) complete an individual prevention plan in Trails, and 3) mark in Trails that an individual child or youth is receiving an evidence-based service.

Caseworkers must be familiar with Colorado’s Family First Candidacy definition. DCW has created a Family First Candidacy Tip Sheet and video introduction that provide caseworkers with best practices and guidance around Family First candidacy scenarios and how each scenario is entered in Trails. If a family/youth have been identified as prevention candidates, caseworkers in Trails will be prompted to complete an individualized prevention plan for each child or youth identified. CDHS’ Division of Child Welfare Staff have created a “Family First: Prevention Scenarios Tipsheet” to provide guidance for county staff around entering individual prevention plans into Trails.

Caseworkers must be familiar with evidence-based programs and services available to children, youth, and families that reside in your community. Caseworkers not only need to know what services are available, but also the target population and desired outcomes of these services so they can make appropriate referrals. Family First eligibility should not be a driver of these decisions, but rather the needs and goals of the child, youth and family.

Note that new IV-E Prevention candidacy is separate from and will not replace the traditional IV-E candidacy for foster care maintenance. Administrative costs can be claimed for two different types of “candidacy” once Family First is implemented:

  1. Traditional IV-E reimbursement for administrative activities related to pursuing the removal, or providing reasonable efforts to prevent the removal, of a candidate for foster care (conditioned on a child being eligible for Title IV-E foster care). This allowable use of Title IV-E Admin will continue to be an allowable use unchanged by Family First, and
  2. New IV-E reimbursement for administrative and training costs related to preventing entry into foster care for ANY child who is a “candidate for foster care” under the state’s candidacy definition.

Learn about Family First eligible prevention services included in Colorado’s plan that you may want to bring to your community

  • The current list of evidence-based programs included in Colorado’s Title IV-E Prevention Program Plan approved by Federal partners is:
    • Nurse-Family Partnership (NFP)
    • Parents as Teachers (PAT)
    • SafeCare
    • Healthy Families America (HFA)
    • Multisystemic Therapy (MST)
    • Functional Family Therapy (FFT)
    • Parent Child Interaction Therapy (PCIT)
    • Fostering Healthy Futures (Preteen)
    • Child First
  • The following services require additional work in order to fully meet Family First requirements such that they can be included in CO’s Prevention Program Plan and expenditures can be claimed by CDHS. Note: These services are already in communities across Colorado and can continue to be delivered and expanded. However, CDHS cannot claim on these services under the Family First expanded entitlement:
    • Trauma-Focused Cognitive Behavioral Therapy (TF-CBT): This service is rated Promising on the Clearinghouse, therefore Colorado needs an ongoing rigorous evaluation plan. The evaluation design needs to be developed. We also need to build data infrastructure to meet fidelity monitoring and CQI requirements.
    • High-Fidelity Wraparound: The Clearinghouse rated this service as “promising” for another state. Colorado also completed an independent systematic review of this service and believes it will have a rating of “promising.” Similar to TF-CBT, we will need an ongoing rigorous evaluation plan in place before it can be added to the State plan. Additionally, this service is currently funded through the federal COACT grant, so we would not be able to claim reimbursement on expenditures at this time.
    • Motivational Interviewing (MI): MI is rated well-supported in the Federal clearinghouse. Colorado is in the process of building a plan for integrating MI into casework practice, as well as designing a framework for claiming for MI when it is used in the delivery of other prevention services (e.g. Colorado Community Response).
  • Directors, supervisors, and your local providers can take advantage of a series of informational sessions on the models recommended for the mental health services array as part of Family First:
    • Fostering Healthy Futures: Recording Link
    • Child First with Parent-Child Interaction Therapy: Recording Link
    • Functional Family Therapy and Multisystemic Therapy: Recording Link
    • Trauma-Focused Cognitive Behavioral Therapy: Recording Link
  • CDHS engaged the Colorado Evaluation and Action Lab at the University of Denver to develop a short- and long-term strategy for expanding Family First-eligible prevention services in Colorado. Access the report: Strategy for the evidence-based aspects of the Family First service continuum. The Lab published an updated annual report in 2022.

Learn about residential substance use disorder treatment programs for parents with children

There are a handful of residential substance use disorder treatment centers for pregnant and parenting women and their children in Colorado. As of May 2021, Colorado has a total of 96 beds available statewide across 6 facilities in Denver, Jefferson, Pueblo, Weld, Arapahoe, and Mesa counties, many of which have waitlists. Each program is slightly different in terms of the age ranges of children that can accompany their parent to treatment (some facilities allow for children up to the age of 12). For the Special Connections program, mom’s can enter treatment when they are pregnant or up to one year postpartum. In addition, moms with preschool- or elementary-aged children are eligible to enter some family-based programs due to Medicaid’s expanded residential SUD benefit that took place January 1, 2021. There is no wrong door for referrals into any of these programs and clients can still be referred to a Special Connections program when there isn’t a program in a client’s region (the program and the client’s RAE can work out single case agreements). A new program is currently being developed in El Paso County and there are other communities that have expressed an interest in and are working toward developing a program locally. For Special Connections programs, treatment is reimbursed by Medicaid and room and board is reimbursed by the local Managed Service Organization. For more information on these programs, visit the Substance Use Services for Pregnant and Parenting Moms section on OBH’s website. You can also reach out to the Office of Behavioral Health (303.866.7400; cdhs_obhfeedback@state.co.us) and/or reach out to your Regional Accountable Entity and Managed Service Organization.

Engage in the work to shape Colorado’s prevention services

  • The Colorado Evaluation and Action Lab has done a preliminary analysis to identify alignment between documented needs within Colorado and evidence-based services rated by the clearinghouse. The report outlines short- and long-term strategy recommendations for implementing and scaling evidence-based practices in Colorado. The Lab published an updated annual report in 2022.
  • Directors can utilize existing forums to mirror some of the state-level conversations around available services, gaps, expansion and service adaptation needs at the local level: Local best practice court teams, local problem solving court committees, local collaborative management programs, local Juvenile Services Planning Committees, and other local collaborative bodies in your community. Utilize your child welfare data to discuss local service needs driving removals and out-of-home placements, with your local prevention partners.
  • Directors are encouraged to participate in or apply for leadership positions for the following opportunities:
    • Colorado Child Abuse Prevention Trust Fund Board. Of the 17 board members, four appointees must represent county leadership, as either a county commissioner or a director of public health or of human or social services; three of whom must have expertise in human service or child welfare practice. This entity will make decisions about how to utilize the prevention drawdown funds the state receives to scale prevention programs by awarding grants through a regular RFP process. Per HB21-1248, the Colorado Human Services Directors Association (CHSDA), Colorado Counties Inc. (CCI) and Colorado Association of Local Public Health Officials (CALPHO) coordinated to appoint four new county leadership representatives to the Board, three of whom have expertise in human services and child welfare practice. The four appointees selected are: Clifford Brown, Director of Public Health, Custer County, OD, MPH, FAAO(D); Mary Berg, Executive Director of Jefferson County Human Services, LCSW; Janet Rowland, County Commissioner, Mesa County; and Martha Johnson, Director, La Plata County Department of Human Services and San Juan County Department of Social Services, LCSW.
    • Child Welfare Prevention Task Group: While the Services Continuum workgroup is no longer meeting, remaining priority tasks and ongoing discussion will now occur within the new Child Welfare Prevention Task Group under Child Welfare SubPAC. The group meets monthly on the 2nd Friday of the month from 1:30-3:50pm. Several subgroups related to Family First have been formed, including: 1) Data and Research Subcommittee; 2) Statewide Prevention Integration Subcommittee; and, 3) County/Region/Local Implementation Subcommittee. All meeting information can be found here.

Explore funding opportunities to build a continuum of prevention programs

Primary, secondary, and tertiary prevention services are expensive to build and sustain. Partnerships with your behavioral health, public health, home visiting, juvenile justice, collaborative management program, and others in your county and/or region will be key. Reach out to and start a conversation with your local providers and state partners at CDHS that oversee respective prevention programs. More information is also available in a recorded lunch and learn session, “Funding to Support Prevention Services and Cross-System Financing Strategies,” hosted in partnership by CDHS and CHSDA: Session Recording and Powerpoint.

  • Counties will continue to use their Child Welfare Block, Core Services Program, Collaborative Management Program and other funding sources, to provide a continuum of prevention services that best meet the needs of families in their communities.
  • Federal Family First Transition Act Funds: The Family First Transition Act provides critical funding and flexibility to ensure a smooth and successful roll-out of Family First in Colorado. CDHS received over $7.7 Million in transition funding to spend flexibly on implementation efforts. Due to the overwhelming interest from stakeholders regarding the use of transition funds, the Department created a diverse 15-member group, 6 of whom represent county human service departments, in July 2020. The group is charged with reviewing and prioritizing funding proposals and developing recommendations for the Department. Funding opportunities on the prevention services side include:
    • From 2020-2023, CDHS will be awarding up to $1.5 million ($500,000 each calendar year) for efforts that align with 1) Expanding the prevention services continuum in a way that addresses locally identified needs, meets Family First requirements, addresses inequities across the state, and emphasizes cultural responsiveness, and/or 2) Addresses known and potential barriers to Family First implementation. CDHS selected awards for the second round of Family First transition fund grants to support local Family First implementation activities in September 2021.More information about the recipients of awards is also available: first round awardees; second round awardees.
  • Federal Title IV-E Prevention in the Colorado Child Abuse Prevention Trust Fund: The new federal reimbursement that Colorado receives on Title IV-E prevention services will be deposited into the Colorado Child Abuse Prevention Trust Fund and distributed via an RFP process for purposes of building and expanding programs and services identified in the federal clearinghouse or under evaluation for purposes of petitioning the federal government for inclusion in the clearinghouse. Note: A separate fund is available within the Trust Fund for mini-grants for training on child sexual abuse prevention and training on strengthening protective factors.
  • Temporary Assistance for Needy Families (TANF): Individual county allocations are derived from Colorado’s county block grant using a formula based on economic and demographic factors. TANF funds beyond basic cash assistance are designed to be flexible and can be used for a wide array of services and supports. County departments of human/social services have flexibility in determining the most effective approach for accomplishing the four federal purposes of TANF within their local area and within the parameters established by the state and federal government (Broad-based eligibility: lawfully present, income under $75,000, and a child in the home). Counties in many cases can use their TANF allocations and local reserves for prevention programs.
  • Title IV-B Promoting Safe and Stable Families: PSSF funds are awarded via an RFP process for purposes of providing family support services, family preservation services, reunification services, and adoption support services. PSSF awards include a match requirement for 30% of all awarded funds. Awards have been granted for the next five-year funding cycle (FFY 2022-2027), which begins October 2021. The next solicitation will be released 2026. Eligible applicants for a PSSF solicitation include County Departments of Social/Human Services, local Government agencies, and any private or not-for-profit community-based organization. Entities that are not a county department of human services will require a letter of support for the county departments of human services in the counties where they will be offering services. 2021 Stimulus funding: Colorado received an additional $847,869 in stimulus funds for PSSF as a part of COVID relief. This one-year funding is likely to support the first cohort of Child First sites. Reach out to Jill Jordan (jill.jordan2@state.co.us) for more information.
  • Medicaid: Coordination with your Regional Accountable Entity (RAE) and Medicaid will be vital. When considering where Medicaid may be able to pay first before other funding streams for Family First prevention services, a good place to start is with a conversation with the RAE and county at the table together. Counties can also reach out to local providers directly. There is also a group working on the claiming logistics in seeking to address Medicaid as the “Payer of first resort.” You can reach out to Brad Borges (bradly.borges@state.co.us), Ann Bartholomew (ann.bartholomew@state.co.us), and Kelly Sawka (kelly.sawka@state.co.us) for more information.
  • Home Visiting: Historically, home visiting programs in Colorado have used a myriad of funding sources to build and sustain services. Colorado uses a combination of the following funding sources to fund different home visiting programs. Counties can reach out to the state intermediaries of respective home visiting programs for more information.
    • Federal Funding Sources: Maternal, Infant, and Early Childhood Home Visiting (MIECHV) program, Medicaid, Temporary Assistance for Needy Families (TANF). Stimulus dollars for the MIECHV program will be available to existing MIECHV sites.
    • State Funding Sources: General fund with line item for specific models; Tobacco or similar taxes dedicated to early childhood support; TGYS; and, Colorado Child Abuse Prevention Trust Fund.
    • Local Funding Sources: County Core dollars, local taxes
    • Private Philanthropy
    • Note: The Home Visiting Investment Task Force began meeting in November 2020 to develop a strategy to scale a continuum of home visiting services in Colorado. After the initial phase of work, the group has been reauthorized to continue with implementation around the Task Force Recommendations and Home Visiting Plan. For more information, please reference the group’s reauthorized charter, membership, and meeting details.
  • Title II of the Federal Child Abuse Prevention and Treatment Act (CAPTA): Community Based Child Abuse Prevention (CBCAP) Funding in Colorado is currently being used to support cohorts of local communities in creating local child maltreatment prevention plans that align with the Colorado Child Maltreatment Prevention Framework for Action. A request for interest for the next cohort of planning sites is anticipated to be released in late 2021. A request for proposals for implementation funding will be released in late 2022 with funding to start in October 2023. Reach out to Essie Santillano (esmeralda.santillano@state.co.us) for more information.
  • Colorado Community Response (CCR) is a voluntary prevention program working with families that have been screened out or assessed and closed without child welfare services. The program was developed around the Strengthening Families Protective Factors Framework to strengthen families and prevent child maltreatment. Program components include strength-based case management, family-driven goal setting, education, and support to improve financial well-being, flex funding, and resource referrals to support goal attainment. The program is awarded through a competitive solicitation. Awards have been granted for the next five-year funding cycle (FFY 2022-2027), which began in July 2021. The next solicitation will be released in 2026. Reach out to Aaron Miller (aaronc.miller@state.co.us) for more information.
  • SafeCare is a voluntary in-home behavioral parenting program that targets risk factors for maltreatment by teaching parents/caregivers skills in three topic areas: home safety, child health, and parent-child/parent-infant interaction. SafeCare targets parents/caregivers of children ages 0 to 5 who have a history of child maltreatment or who have risk factors that may lead to maltreatment. As of July 2021, SafeCare is available in 38 counties across Colorado and is supported by the Kempe Center as the state intermediary. SafeCare is funded by state general funds.
  • Colorado’s Tony Grampsas Youth Services Program (TYGS): Funds are provided to community-based organizations that serve children, youth and their families with programs designed to reduce youth crime and violence, youth marijuana use and prevent child abuse and neglect and school dropout. Eligible TGYS applicants include local governments, schools, nonprofit organizations, state agencies and institutions of higher education. TGYS operates on a three-year grant cycle. The current grant cycle runs July 1, 2020 through June 30, 2023. Contact Kristi Griffith (kristi.griffith@state.co.us) for more information.
  • Local CYDC Funding: The Colorado Youth Detention Continuum (CYDC) is implemented locally within each of the state’s 22 judicial districts. The Colorado General Assembly appropriates funds for CYDC programming and the Statewide Advisory Board is responsible for developing an allocation formula and allocating the funds. Jurisdictions use their allocations for a variety of purposes, including in some cases, providing treatment services to prevent or shorten out-of-home placement and further penetration into the system. Each local CYDC program has a Juvenile Services Planning Committee (JSPC) and a local coordinator to oversee implementation of local CYDC services.
  • Behavioral Health: CDHS’s Office of Behavioral Health (OBH) has previously released solicitations for the High Risk Families Cash Fund to support capacity for and provide services to high-risk parents, including pregnant and parenting women, and for services for high-risk children and youth with behavioral health disorders.
  • The Colorado Partnership for Thriving Families (CPTF) aims to significantly reduce child fatalities and child maltreatment for all children zero to five by positively and proactively supporting strong and healthy family formation. The partnership’s three main priorities are: 1) Systems Alignment: Align state and county human services, public health, and health care systems to place family well-being at the center. Focus on funding, data, and policy across systems; 2) Early Touch Points: Strengthen the well-being system service array to improve outcomes for parents and infants throughout pregnancy and the first year of life; and 3) Community Norms: Change community norms related to social connectedness to increase access to information on child development and informal support with parenting with the intent to reduce parental stress and decrease child maltreatment. Counties can engage via three levels–participate, magnify and/or demonstrate–on any or all priority areas. Demonstration sites receive technical support and may be eligible to receive funding for projects. This resource for county directors provides specific examples of ways to engage w/ CPTF and what the Partnership offers, as well as current demonstration site projects and upcoming opportunities. Email Krishna Dahya (kdahya@illuminatecolorado.org) for more information about engaging in the Partnership.
  • Private Philanthropy

Access more information on understanding financial claiming for prevention services under Family First

In August 2021, the Colorado Department of Human Services and the Colorado Human Services Directors Association hosted a four-part discussion series about how claiming for prevention services under Family First will work in Colorado. Presentations, recordings and a follow-up Q&A are available on this page.

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Colorado’s Family First Implementation Guide for County Directors is a collaboration between the  Colorado Department of Human Services and the Colorado Human Services Directors Association.