Effective Sept. 30, 2021, Family First Prevention Services Act (FFPSA) established new requirements for placements in congregate care facilities certified as qualified residential treatment programs (QRTP) including completion of QRTP assessments by qualified individuals (QIs).
Department staff are providing clarification to county and tribal case workers on the QI request and QRTP assessment process.
Basic steps for implementing QRTP assessment process
Step 1: Case worker sends email request to department staff for a state sponsored QI immediately after juvenile treatment screening recommendation to place in QRTP or when placement in a QRTP occurs due to crisis.
Step 2: Case worker assembles a family and permanency team as soon as possible or within 10 days of juvenile treatment screening team recommending placement in a QRTP or when placement in a QRTP occurs due to crisis.
Step 3: Department staff responses to request and if the request is within the required timeframe staff will work to assign a state QI.
Step 4: When a request is assigned to a QI, case worker sends state QI all of the required referral information as soon as possible and no later than 5 days.
Step 5: State QI completes QRTP assessment and sends recommendation to case worker before or on the date the assessment is due.
County and tribes participating in the American Indian Child Welfare Initiative (Initiative) are expected to utilize their contracted QIs and/or employees they have approved under one of the federal waivers prior to submitting a request for a state QI.
If an agency is unable to use their own QIs, due to conflict of interest or availability, a request can be made to the state sponsored program within the required request timeline. In the request, agencies should note the reason they are unable to utilize their own QI. These requests must be sent within the required timeline.
A new QI request form is being developed for case workers to use when requesting a state sponsored QI. See the Qualified Individual webpage for the most updated QI request information and documents.
Completed requests are emailed to: ffpsa.qualifiedindividual.DHS@state.mn.us
When a request is received an automatic email response will be sent to the agency as receipt confirmation from the department. A follow-up email will be sent as soon as possible or within 2 business days and provide information regarding next steps. Additional follow-up communication may also be needed between the department and agencies to clarify information after a request is received. A prompt response to these emails is necessary.
Assignment of a QI may depend on QI availability, priority timing needs, and needs of children and family.
Request must be submitted no later than 15 business days
If a request for a state QI is not received before or on the 15th business day from the date a child was placed in a QRTP, the request will be declined.
State sponsored QI’s are individuals who have contracted with the department to provide this service for counties and tribes. This is not a full-time job and their availability fluctuates.
This deadline is necessary because state and federal law require that a QRTP assessment must be completed prior to a QRTP placement or within 30 days of placement if it occurs due to a crisis.
To ensure a QI can complete a QRTP assessment within the required timeframe, case workers must submit a request for a state sponsored QI to department staff no later than 15 business days from the date of placement. This ensures assigned QIs have adequate time to complete a comprehensive assessment.
Case workers are strongly encouraged to request a state sponsored QI immediately following the approval of a QRTP placement by the juvenile treatment screening team.
Additional information and/or follow-up communication may be needed after a request is received; so timely response is important to ensure timelines are met.
All required referral information including contact information (i.e., child, parents, and members of the family and permanency team) must be provided to the assigned QI as soon as possible and no later than 5 days
Releases of Information not required
County and Initiative tribes are no longer required to have parents sign releases of information (ROI’s) in order for a QI to interview the child, child’s parents and family and permanency team members. Agencies can disclose welfare data about a child to qualified individuals because that information is required to comply with a federal program and funding. Qualified Individuals are considered child welfare personnel and are using data to coordinate and evaluate the need for services under Minnesota Statutes, section 13.46, subdivision 2(5)-(7). No release of information is needed for a QI to contact the child and family and permanency team because the QI is required to do so in order to comply with FFPSA. Program documents and resources will be updated to reflect this change moving forward.
Assemble the family and permanency team during the juvenile treatment screening team
Completing QRTP assessments require QIs to engage with the child, and child’s family and permanency team members.
During a juvenile treatment screening team meeting, when it is anticipated a placement in a QRTP will be recommended, a case worker is encouraged to consult with the parents, and child if over 14, regarding recommend membership of a family and permanency team. Preparing for the QRTP assessment during the juvenile treatment screening team supports family engagement in the membership of a family and permanency team and supports a thorough QRTP assessment.
The QRTP assessments must be completed in consultation (interviews) with the child, the child’s parents, and the family and permanency team members. It is imperative for a QI to have a diverse group of individuals to consult with so a QI has an understanding of a child’s needs and strengths. Information gathered by the QI will assist in determining the most appropriate and least restrictive placement setting for a child.
The family and permanency team should include family members and supportive individuals who can best speak to the child’s strengths and needs.
This includes:
- All appropriate biological family members, child parent's, legal guardians, custodians and relatives as defined in section 007, subdivisions 26band 27
- Foster care providers, and
- Appropriate professionals who are resources to children's family, including teachers, medical providers, mental health providers, clergy, etc.
Children age 14 or older, can select a person to be part of the family and permanency team.
For American Indian children, agencies must make active efforts to include children's tribal representative.
To document the family and permanency team membership, county and tribal agency staff should utilize the “QRTP family and permanency team” screen in SSIS under the Permanency node. A copy of the list is provided to the QI upon QRTP assessment referral. See QRTP- family and permanency team-H5P.com and QRTP family and permanency team job aid.
Additional resource documents regarding specialized setting, QI best practices and QRTP assessments are currently being developed and will be available soon on FFPSA County Link web page.
For detailed information on the QI and QRTP assessment see bulletin 21-68-22, Family First Prevention Services Act: Qualified residential treatment program (QRTP) assessment.
For information on the family and permanency team see Family and Permanency Team practice guide, DHS-8120B (PDF)
Webinars and published guidance are available for agency staff to understand and implement required federal changes on the Child Welfare Training Academy’s FFPSA webpage at https://mnchildwelfaretraining.com/more/ffpsa/
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