 Good afternoon. This is January 28th, and you are watching House Human Services Committee in the afternoon, and we are hearing from the Department of Children and Families within the Agency of Human Services. The Family First Prevention Services Act, both an overview of the legislation and what to date the department has done in terms of the planning. With us today we have the Commissioner Sean Brown, Department of Children and Families, and Brenda Gully, who is the Operations Manager, or I've got your title wrong, I apologize. But she's a very important person because a long time ago she was my student. And with that, I will turn it over to the Commissioner to introduce and move forward. Thank you. I appreciate the opportunity to be with the committee today. As you indicated, Brenda Gully, our Director of Operations for the Family Services Division will be leading the committee through the PowerPoint and the legislation, and then we're the team is here to answer questions also here as Sarah Truckel, our Chief Financial Officer, because there are a lot of financial tentacles to this new federal legislation, and I think it's important to understand them the best we can and help explain them to the committee. Take it away. And if you can set the stage in terms of whether you want questions in the beginning or whether you would like us to hold questions until you're finished that I will just let me know. Very good. Thank you and good afternoon, everyone. I am Brenda Gully, the Director of Operations for the Family Services Division of DCF, and it's my pleasure to be with you here this afternoon, along with Commissioner Brown and our Business Office Director Sarah Truckel. And I'm happy to take questions throughout the presentation, as well as the DCF team here. And we do have a PowerPoint presentation for you this afternoon to take you through some of the key aspects of the Family First Prevention Services Act. So I think it would be good to start that PowerPoint at this point. Thank you. And so that's the team and I think we can move on to the first slide that gives a bit of an overview of the legislation. So the Family First Prevention Services Act is federal legislation that was passed in 2018, and it is considered to be one of the most substantial pieces of federal legislation impacting cell welfare across the nation in the past 20 years. So Family First is about Title IV-E funding, so Title IV-E of the Social Security Act, and Title IV-E is the most substantial funding stream or child welfare work that occurs across the nation. So child welfare work is those dollars go to fund the salaries of Family Services staff, they fund all of our foster care placements, all of our residential care placements. So when we say it's the most substantial funding stream, we mean specifically for services for children that are in DCF custody. This law is really about changing how those dollars are drawn down by states. So the overarching goal of the federal government when the federal government looks at the dollars that are given to states, 90% of the 40 dollars across the nation are currently being spent on the children that are in DCF custody, and about 10% on prevention. So part of the intention of the federal government is to really flip that so that more of the funding from the federal government to states is on prevention of children coming into DCF custody and ultimately reducing the number of children in DCF custody by investing in prevention of that occurring. So that's really the overarching goal and then we're going to spend a little bit of time talking about how that's going to occur. So on slide three, you'll see that what we're really talking about here on the prevention side is this is new money. So this is new money from the federal government to states to invest in prevention of children coming into DCF custody. This is this is the carrot, if you will. So the carrot is it comes with strings of course that are very clear about here are the ways that states can draw down money for prevention of children coming into care. And it's very specifically talking about that states need to define. Here are the children that are at risk of coming into custody. Here are the evidence based programs that can be provided for those children. And here's the case planning and evaluation and monitoring that will occur to know that these programs really are preventing children from coming into care. And the prevention part of it is broken down into home based services, substance use related services and mental health related services. On the next slide we talk about the stick part of it. And I say the stick part of it to say that it's very clear for all states across the nation that there is federal money that states have been drawing down that they will no longer be able to draw down effective October 1 of 2021 in Vermont. Unless we have certain pieces in place. And this is with regard to youth in residential level care that are in DCF custody. So in the state of Vermont today we have about 150 kids in DCF custody about half are in residential care within the state of Vermont, and about half are in out of state residential placements. So we draw down $40 for the for the majority of those, those youth today. As of October 1 unless we make certain key changes, we will no longer be able to draw down those funds for those youth. And one of the more substantial changes that would need to occur is for the residential programs that are providing that service to be what's called qualified residential treatment programs. And so for those residential programs to achieve that status. There's certain things that they need to have in place. They need to be an accredited program. They need to have 24 seven nursing care. They need to provide trauma informed programming, family inclusive programming, and six months of after care. So that's something important to bear in mind because of course each and every one of those pieces requires a certain amount of money and preparedness for that to occur. In the next slide, we spend a little bit more time talking about some of the pieces that need to be in place in order to be able to draw down those federal dollars for those those youth in residential programs. So key areas to highlight these are additional pieces that must be in place for that to occur. There is that there would need to be a 30 day clinical evaluation that says yes, this youth really does need residential care. And the other is a judicial review that would take place at the 60 day mark, where the court is reviewing and approving the residential placement. That second piece is pretty significant. When we think about the significant backlog that we have in our court system today. And we estimate approximately 400 additional hearings per year would need to occur in our chins system in order to be able to absorb this new requirement. So let's jump in and add that currently we only need judicial approval when we want to place a youth out of state. So this would really impact in state placements moving forward because we already are required under federal compacts to get judicial approval to move kids out into programs out of state. So that talks a little bit about some of the readiness work that we need to do. So the first piece is really looking at so for the, the 12 agencies in Vermont really 35 different programs that we license. What would it take for them to be ready to become qualified residential treatment programs. So our residential licensing and special investigation unit is in the process of conducting that readiness assessment with all of our agency programs. The other piece of readiness assessment that's occurring is looking at, you know, financially, what would it take for these programs to be able to get to up to speed at this level. And then the third piece of readiness work that we're doing is the development of our prevention plan. So looking you know within the state of Vermont. What is the foundation that we already have of prevention programs that could potentially qualify in the eyes of the federal government to be family first prevention services prevention programs. And then there's the evaluation where we're already able to demonstrate these are children and youth at risk of coming into custody, and what level of, you know, case planning and evaluation and monitoring, are we able to put in place by October first, in order to draw down the for you prevention dollars as part of our ff PSA prevention plan. In slide seven, we continue to talk about some of those operational impacts. So I want to pause here and say that slide seven talks about what I consider to be one of our most significant barriers to drawing down any, any of the 40 dollars. And that is that we need to have the database that can turn for a on and off at the right time. So we do get audited on every 40 dollar that we draw down in Vermont, and you know, having systems in place that ensure that we are drawing down for we for children or youth that are for eligible, and that are in placement for eligible is part of what we have in place currently around all of the children and youth in DCF custody that are in paid placement. We would need to extend that to the population of children and youth that are either receiving prevention services, or that are in residential level care moving forward. And we do not currently have a database that has the right mechanisms in place for that to occur. And I know that the legislature has heard quite a bit of testimony on the fact that the family services division utilizes social services master index system from 1982. So it's a very old database that is not currently capable of drawing down any of the FF PSA dollars that we would need to draw down. So that's a pretty significant barrier that we would need to overcome. We would need to get those pieces in place for that 30 day clinical review to occur. We do have on staff, a new DCF clinical director, who is potentially available to provide that role. So we would need to have the 60 day judicial review for approximately 400 additional court hearings per year. And then we would need to do the cost analysis that really looks at you know what is the cost to get all of these residential programs up to speed, our database up to a level where it can provide the for a draw down that's needed. You know, does that outweigh the benefit of being able to draw down these new 40 dollars. So on the next slide. We wanted to just summarize the financial impacts for all of this. So this is really again just recapping we have the database, the internal work that we're needing to do to assess all of this. So the provider impacts right so knowing within our community of both prevention programs and residential programs. What does it mean for them to get up to speed to provide the level of quality service that is required through the FF PSA. The judiciary impacts and the cost of that. And then the costs associated with the clinical assessments that need to occur. So, so we have estimated approximately $1.3 million cost for the, I should say lost really on on the residential side as of October 1. And then we're in the process of estimating the cost to be in compliance of the FF PSA, as well as really the mechanisms that would need to be in place in order for that to occur. So that's a lot of information very quickly. And I think at this point, we can just pause and ask whatever questions you might have about all of this. We have some questions and we have a question by representative Redmond then representative would. Thank you Madam chair, just a question about the clinical assessment. Are we not doing those presently and I'm just curious what the distinction is between how we do them now and and what we would be doing going forward. So within Vermont, we do currently have a state interagency team and there is a subcommittee, the central review committee that does provide interagency review of all children and youth in the state of Vermont that need residential level care. And that process is extensive requires a local team to convene requires a level of mental health, education, family services, and community involvement and review of anything that is possible to support that child or youth being safely within the community. So the scrutiny of is is residential care really necessary, you know what is the least restrictive environment that a child or youth can be placed in. So we are hopeful that we can build on that. The federal government requires that the review is done by someone neutral with expertise outside of the child welfare agency, and currently, you know we are a part of that central review committee. And so we're hoping what what we are able to do is actually submit a waiver to the federal government to say here's what we do currently, there's what we could add to it, be within compliance, and hopefully, you know, have something that is is acceptable to the Children's Bureau and works within the family services and Vermont system. Thank you Madam Chair. Well that was one of my questions was how how the. We learned earlier about the clinician on staff. That was had been transferred to the central office and I was trying to figure out how that would be independent but you sort of described your process that you're looking at. I'm recalling. This is sort of having to do with the judicial review aspect of this and having had some experience with requirements for judicial review when we close Brandon training school many years ago. I'm familiar somewhat with that, just the context of that and it does indeed take a lot of time and staff resources, and that what I'm recalling is that we did have some money set aside for some chins. Improvements modifications modernization dealing with the court system and I I'm also recalling that we tapped some of that money last year but I for a different purpose but can you speak a little bit to you know where we're at with that because there was a whole group looking at how the judiciary could more effectively and efficiently get through not only the backlog but now looking at these new requirements and then I just have one other follow up. Certainly, I mean I believe you're referring to the chins reform effort, and I would say that the, the work of the chins reform effort is very much aligned with the intention behind the Family First Prevention Services Act that it that both of both are looking at what can we do to ensure that children do not need to come into custody, you know, basically if children are able to safely remain in the home, we want them to be able to do that. And so what can we invest in in our prevention services that can help keep kids safely at home. One of the really key places of alignment that I think is incredibly exciting is that in Vermont, we have one of our programs parents as teachers is actually on the Family First Prevention Services Act clearinghouse, which means that is a program that we are now using that funding to pilot and expand that in Vermont, and there will be the opportunity through the FFPSA to have federal drawdown for that program for years to come. So that'd be an example of some of the great synergy that can happen here. And then I think, and just to jump in here and Brenda, please feel free to fill in the gaps that I'll leave on this, but some additional monies were allocated earlier in the court use that to create a judicial master role as well. And Brenda, I didn't know if you want to explain kind of where that's at right now. Certainly in Vermont judicial master is being piloted in Chittenden County and Franklin County. And that is one of the, one of the ways that potentially we can use that judicial master to look at are there cases that might otherwise get, you know, take many months to get through the court system. And sometimes because of contested hearing sometimes because of a backlog of of cases that need to be heard in the court. And so the judicial master can hear those cases and move them along faster. And so it's, it's, it's an opportunity to really streamline some of the cases and really ensure that there's a more timely process. Thank you. And then my follow up was really looking at, I appreciate that you're looking at a sort of a cost benefit analysis of what does it take to come into compliance versus what we lose in federal resources. And that seems that would seem to be, you know, part of the picture but I guess I'm interested in both your, your thoughts and the commissioner's thoughts about, you know, when it comes down to children and families, do you believe that the changes that have been made in this federal act are beneficial for Vermont's children and families. And so there's, there's one thing about cost but then it is really trying to look at the also the welfare of families. So, so if I could jump in here thank you for your question representative would I think it's a good one. I think if you look at the intent of the federal law and kind of making it harder and that increased level of review when you want to use higher ends of care for children. And the opportunities that it's really looking at expanding funding opportunities for prevention services. And if you really think about our work. That's what it's about is keeping families together keeping kids safe and reducing, you know, their trauma. So, you know, whatever they might experience through abuse and neglect but let's be honest there's a trauma of going through the system as well and coming into custody and going through a foster home and whatnot so if you look at the intent of that legislation is rich really to keep families in the act. I think there is a benefit, you know, to the legislation that way that is really shifting the focus and trying to move states to shift their practice from reactive to to proactive and keeping families together and reducing harm to kids and trauma to kids. So, from that perspective, I think there's a lot of value in that. And I think that over time that that could really help Vermont's children and families over the long term. I mean that's what the Chins reform work groups about. I mean we've been trying to focus on that. But now this opens up a new pot of funding to actually kind of support that work. Although it does come, as you've heard, with some requirements and you know they need to be evidence based practices they need to be able to collect and show that they're reducing kid those practices and whatever programs we're standing up on the prevention side are reducing kids coming into custody. And so anyone who knows our data systems in the state are challenged to begin with. And then also many of our providers are smaller. And to put those systems in place to kind of capture that data and report that data is a heavy lift. And then also there's some requirement and then on the other side, you know, it really is going to make it more challenging for us for kids that really do need that higher level of care there are more hoops to jump through now than we had before. And so that that that's where the cost analysis comes in but I so I don't look at it in a cost benefit dollars wise I just look at that that the law is really trying to get states to reflect on their systems of care and let's try to shift it to keep prevention instead of, you know, reacting to the to the harm that's already occurred let's prevent it. And so in that sense I think it's a great opportunity for the state here. And Brenda, if you want to add anything. Yes, I would add I think we're really proud in Vermont that in the last few years we've reduced the number of children in custody in residential level care by 20%. And so, so we have, I think a really solid foundation interagency foundation of working to ensure that youth only go to residential care if they really need to and that they, they stay for they go into the right program for the right length of time. So I think that foundation is very helpful in terms of the implementation of the FFPS a moving forward. And I also think it's, I think of it as like we're at the infancy stage right year one, and FFPS a is going to impact states for years to come. So what we do today is probably very small compared to five years from now 10 years from now, how much federal monies were able to draw down, because over time will be able to build up more of our prevention foundation. So there actually is not a limit on the, the amount of federal monies that you can draw down. It just needs to be in in a way that meets all of the federal requirements. So I think the law is here to stay I think over time, our capacity to tap the benefit of it on behalf of Vermont will grow. Thank you. I have other questions but I'll let other folks have their time. If you, if you might just want to define what residential care means because I'm not sure that everybody here would have the same understanding of that. So residential care sometimes also referred to as congregate care, typically means a youth being placed in a staffed long term treatment program, sometimes distinguished from a short term like a crisis stabilization type setting. So I would distinguish it from, you know, a battle bro retreat psychiatric stay, or a group home. So, so programs within Vermont would be Park Street or Howard Center back it, you know there are there are programs that have maybe five or 10 years, other programs that have dozens and you know out of state out of region, there are some residential programs that have hundreds of youth in their program not foster care correct. Right I would distinguish it from foster care which is a family based setting where it's not staffed it's it's truly a household. I'm small before we go on to your question and represent from said, I want to interject a question or two that at one point was following the questions of representative would clearly us being able to implement this plan requires it and requires judicial investments. I notice on your implementation plan, there is no one, nothing, it does not appear to be anyone from it, nor does appear to be anyone from the judiciary. So, I'm curious as to how this is going to happen in a vacuum. So, if I could jump in here, thank you. You know, as you as you heard earlier, this legislation passed in 2018 and gave states several years to implement. And we chose not to implement early took a buy for two years and so we lost the ability during those two years to use the, the, and, and the law was hard. Yeah, I was just going to say, I think it took us a while to understand it's a complicated piece of legislation and expansive piece of legislation. So just kind of understanding, getting an understanding takes time. And then I, and, and I think as you do those calculate started that understanding we recognize there were some cost benefit analysis and that there were going to be costs to the state in terms of, you know, to implement this and the impact on our system could be quite large. And so as we move forward, where, who was on this implementation team that will enable us to implement it. Yes, so if I could, I think our implementation was way laid by the pandemic and are needing to pivot to respond to the demands of the pandemic and I think we are now reshifting our focus and we've created a project team within the community that is pulling resources from our business application support unit, our top line project manager, we are engaging with it to understand whether we can make fixes to our current child welfare information system to capture that data or are we going to make a new one as you know there's been a, there's been conversations across the department that all of our IT systems are in dire need and so I think it's just up to now been a prioritization. I think the committee is trying to fix the benefit program problems with the access system. You know we are moving forward now with a new beef is system, you know for the child care system that is literally following apart before our eyes and taking incredible amount of work around all the CWIS system is ancient, it's working, but we certainly need to either make some enhancements so that we can capture the data and put the pieces in place to track the federal funding and when we can, when we can avail ourselves of it and when we cannot, we really need to be able to do that very closely. So commissioner, thank you. Yes, I'm not criticizing. No, no, I'm just trying to put the context. And I was just asking who is on the team. And I was looking at the slide slide nine. And so to to try to remove the, you know, feeling that you need to be explaining the last bullet says a work plan has been developed. So if you would share that work plan with us, that would be very helpful. And then we will ask more questions. So my apologies for misunderstanding your question. You'd want to share those kind of dig, dig into the work plan that'd be helpful. Because then we can ask the questions like who was on it and why aren't they and where are the, for instance, where are families, where are providers. Where are they on and they may be all there. And so if you share with us the work plan on that would be very helpful. Now I'd be happy to and I think what you'll see is that there are, so there is the work plan and within that are the subcommittees that will be forming. So, so the broader work that you're describing has not occurred yet but it is part of the work plan. Yeah, I just want to clarify one thing which is just so folks understand when the law went into effect states were not given the option of accessing the prevention part and not the residential part. So if we were to try to draw down for a money sooner. We would also immediately be penalized. So we would have immediately lost the $1.3 million a year. In my mind that was the main driver for why we did not move forward in 2018. There's like, turn sick context, we have lots of questions from other people. So I'm representative small and then representative Bromstead. Thank you Madam chair. I hope this one is an easy one. Looking at the judicial review, what is the purpose of the judicial review. The purpose is the approval of the placement. So it's really just, you know, wanting its checks and balances in the system so beyond the child welfare child placing agency, having a judicial approval is residential placement really necessary. May I ask the question in a different way. Is judicial review required by the federal by in general federal legislation as it relates to child abuse and neglect or is judicial review required by this law or is it required by state law or organizational policy. It depends on the both in different areas it depends on the decision point along the way. So if the decision about should this child come into DCF custody, certainly judicial review required both state and federal legislation requiring that with regard to the ffps a that specifically requires judicial review for the purposes of placement in residential level care which is new. The states have always required that Vermont has not Vermont has had the authority with for purposes of placement with the custodian. The exception being out of state residential, which is part of interstate compact law that for a state to place a child or youth in an out of state residential program that has required judicial review. It's a national requirement that Vermont then of course complies with. Thank you. Representative small I interrupted your questions, do you have more. All of the other ones were asked in the process. Thank you. Okay. Representative from stead and then representative Redmond. Thank you madam chair and most of my questions were asked by you so thank you. I was curious about that two year why wait two years so thank you for responding to that and my question I guess in my experience when the federal government asks us to change a program as in a speak of a change as it sounds like this is. I do give some planning dollars to move forward and bring together the right stakeholders and do all those sort of things. So, when you decided to wait two years does that mean that the planning had to wait to and so there hasn't been any funds to the state. For those two years or. No, so Vermont did receive $900,000 in FF PSA transition funds. We have started to spend those funds. One of the first things that we did was invest in public consulting group, providing an analysis of our system of care and recommended improvements to the system. We have also use those funds to invest in a team to come together to do some of the business analysis of FF PSA implementation. And then we have funding that's been spent with regard to kin navigation. We haven't talked too much about kin navigation here but FF PSA a pretty significant component of it is working with extended family and really ensuring that states are making every effort to engage with extended family and to support them in preventing children from coming into care and then also once they are in care, being an active part of the care of those children and youth. So there's there's a variety of investments and just remind me on the acronyms what they stand for just to be sure I'm thinking the right FN. So it's FF PSA is the family first prevention services act. Okay, I just want to thank you. Brenda, you will kill more things that now you can send you talked about how you used the prevention planning dollars and the first thing you said is you the department sorry I shouldn't ask you commissioner. The first part they were used for was an analysis or an evaluation of our system and some suggestions. We'd love to see that please. Absolutely I think we just received the final report on that and so we're happy to share that with the committee and maybe even come in and give a review of that and the data contained in that report, just provide some additional context and that would be great. And if we could have it before we schedule you that can be assigned homework. Yes. Representative brumsted did you have any additional questions. Thanks Madam chair, a question about the nursing component I remember when we were meeting as joint protection oversight child protection oversight there was a whole question around the 24 seven nursing care and the fact that in Vermont, our programs are so much smaller than you know like a program in the city where that might make sense and I'm curious, you know, I know that there was talk about seeing if we could, you know, have a different kind of arrangement I don't know where any of that is and how we feel we can comply with that. And Vermont does participate in a national collaborative that so we're able to see how are other states managing this and there's a lot of energy for rural states small rural states, and the solutions that they're coming coming up within that and the federal government has clarified that states are able to create a basically an agreement amongst multiple residential providers that say for example you have a cadre of five nurses that are willing to work together to provide 24 seven support to 10 residential programs. So something like that is potentially acceptable. So, so the requirement is that the nursing staff is available. It is not required that they are physically on site in the residential program. So we do have a little bit more flexibility now, then we understood when the law was first passed. So, did that answer your question. I'm going back to the slides, and maybe this is part of the analysis that's being done now. But as you're looking at the policy and programmatic impact. Do we know yet. And I can't believe I'm asking dollars and not asking the impact on kids, but I'll ask that later. Do we know how many of our programs are accredited programs have to be accredited. So right now, none of our programs are qualified residential treatment programs. And, and in terms of credit accreditation. Some of our programs have some level of accreditation but not necessarily ff PSA acceptable level of accreditation. So how long in the world of academia, our programs have to be accredited and it takes over a year to pull all that stuff together. So, how have we as a state been supporting prodding residential, our residential programs. So our residential licensing and special investigation unit has met with all of the residential programs in the state of Vermont, to review with them, the qualified residential treatment program requirements, including accreditation, nursing after care all components and conducted readiness assessment that looks that here's what you would need. What would it take financially for you to invest in moving in this direction. Larger programs like Beckett are well on their way in moving in that direction. Other smaller programs are not necessarily concluding that they're able to move in that direction. We, we do have a document that RLSI is in the process of writing it's not written yet it's not I don't have it yet. So RLSI I'm sorry our residential licensing and special investigation unit that has been conducting the RTP qualified residential treatment program readiness assessment. They are almost done. And they I would say within a month they should have the write up of the QRTP assessment. So that will be in March. And the plan has to be approved or just submitted by October. The prevention plan has to be approved. Well it can be approved at any time. We can start drawing down FFPS a monies as early as October 1, but any plan can be submitted at any time. We will no longer be able to draw down $40 for youth placed in residential programs as of October 1, unless we're in compliance with all the pieces that I've outlined here. So how this may be a question. Commissioner, but sorry friend I'm not sure. It may be a question for Sarah Truckel. What do we spend what how many 40 dollars. How much 40 dollars are going right now currently to residential treatment. I can get you the exact amount that goes breaks out between in-state and out of state but they're not all 40 dollars what we've estimated for FY 22 which you see in the governor's proposed budget is a decrease in 40 revenue of somewhere around $1.3 million and we are back filling that with general fund in anticipation of the loss of those federal funds at this point. Okay so to to to put that perhaps bluntly, you are planning the budget assumes that we're not going that we are going to be that we're not going to make the October deadline federal deadline. And so we're going to take a financial hit in the 40 dollars. The financial hit for the 40 dollars the 1.3 million looks at our in-state residential programs we are assuming that our out of state residential programs will be compliant with FFPS a in the QRTP requirements because they are larger programs so we are not currently anticipating a revenue shortfall in our out of state placements just our in-state placements and that's what we've accounted for in the budget. And I would also just point out that not all of our our residential treatment providers leverage for E there are some that are Medicaid funded and they will not be impacted by this. And I think I would point out that even if we're able to come, you know, implement this plan get our plan approved by the federal government and minimize of any financial impact that there are providers that we currently use that we will still need to implement that may never be able to meet the stringent qualified residential treatment. Yeah, you know and so that so those are that that's kind of that calculation you have to look at. Yeah, because I mean if I remember back two years ago when we first started talking to be a qualified residential center for the most part doesn't really reflect the way that the bulk of our resident many of our residential centers worked and that perhaps they were more directed towards the larger residential treatment centers. So that was one of the one of the challenges. Okay. Committee what other what questions do we have or what what information, because this is the, this is clearly not the only time we will be talking about this one we've asked for some some information and for some reports. If you can give that to us. The two, at least the two right now and anything else we haven't asked for that are, you know, one is a copy of your work plan. And the other is that report from the consultant. There's sort of information that will that will help us as we go forward and also help us look at the budget. Representative Redmond. One of the questions or one of the points made earlier this morning in testimony by one of our witnesses was about youth voice and youth, youth having a voice or being able to weigh in and I'm wondering where that how that factors in here where I don't know if it first has that as part of its kind of model or if there's a way that we in Vermont are are figuring out how to do that but I thought it was a valid and important point. I would say representative Redmond and please correct me if I'm wrong. Commissioner or Brenda, there were, they've identified that they have a work plan, and they have identified that there is an internal group that only included some, I want to say a DCF and family services personnel. And Brenda was talking about how perhaps the slide was not full, and that the work plan might indicate who was on there. And I think fair warning, if you don't have community providers and you don't have participants, we're going to be asking where they are. I mean one point of clarification in terms of the evaluation and report that the public consulting, public consulting group did that did include focus groups and that did include youth and providers and staff. And the work is also being done in partnership with the National Center for States, and that also includes parent voice and we are now bringing youth voice onto that team. And the work plan includes the National, you know, constituent voice that's being brought into that team. And then of course, as you said, and the work plan includes engagement broad engagement of stakeholders and direct service, we, you know, lived experience as individuals. I think it'll just be really helpful for us to. And it might be helpful for you because we'll stop asking you lots of questions is if we see some of the specifics and then we'll ask you questions. Representative small. Commissioner, I want to see if I am understanding you correctly when it comes to the funding piece. So you mentioned that we can draw both for funding as well as or maybe an opposite to Medicaid funding for youth. And if so, what would differentiate why we would why we would use for funding versus Medicaid. Well, it's a very complicated. It's really the level of service being provided and how it's being provided. And so, and it's very complex and so I'll let Sarah kind of try to explain that a little bit how the funding breaks and how you qualify for different funding streams based on what how you're providing your service. I will do my best to kind of give a high level answer. And then I'm happy to provide some more details if that's helpful to but so for the starters for is a pair of last resort under FF PSA so that's important so if we're drawing down Medicaid we can't then also draw down for you. In addition, we cannot use our what we have historically uses our investment dollars are MCO so Medicaid investment under our 1115 waiver for room and board anymore. So we used to leverage Medicaid investment to pay for our residential room and board and we can't do that anymore. However, we can use for e to pay for some of those costs so there's a lot of different funding streams. Furthermore, depending on the type of provider that you are depends on whether or not you're a Medicaid eligible provider or you're not. So when we were talking about some of our out of state providers. We also have this requirement under FF PSA which is a qualified residential treatment provider. We also have some providers are PRTF providers who would leverage just Medicaid dollars so depending on the type of provider and the whether the services that they provide would identify whether or not they can draw down Medicaid funds and for which purposes, and then it also depends on if we're currently using those funds or not so another big point on FF PSA is that we can't supplant the funds so it's all we can expand programs we can do things in addition expand the population but we can't backfill or use FF PSA funds or those for E dollars to supplant or replace our state funds so they can only expand those and then the other side of that. That comes in is that for he also has a match requirement right so there's a state share to that federal draw down. But if you're interested I'm happy to send you kind of what is our system of care which is like our PMI providers are private non medical institutions who pull down a Medicaid rate. I'm also happy to provide you with what are some of the other providers like Dale PRTF providers and how their funding streams work to just give you kind of that breakdown it's it's pretty complicated but if that would be helpful I can definitely pull that together. That would be helpful thank you. Happy to share. And, Sarah I don't know whether you'd be the person to answer this question or whether these are. It's better for Brenda or the commissioner to answer. For a depends upon their multiple decisions but one of which is what is the type of residential facility. So what is so for those of us on the committee who are more into people and less into dollars. What is the difference between those two. One is Medicaid and it is attached probably to have to be more a little bit more healthcare or whatever. And what is for a comes out so security act. So when I say PRTF I'm talking a psychiatric residential treatment facility. So that would be a Medicaid facility. When I'm thinking of our PMI system and then drawing down different rates. There may be a Medicaid treatment component to that but we're not talking the room and board side of it. Okay, so, so maybe if Brenda could talk about the people or commissioner. Yes, I mean I would say when you think about if the 12 or so residential programs within Vermont, the majority of those are what we're talking about here in terms of becoming QRTP, whereas a program like the Brattleboro retreat. Right that's that's a psychiatric facility. So we, we don't have a psychiatric residential treatment program, other than the Brattleboro retreat in Vermont that we're using for placement of youth within the state, but we certainly do place youth out of state in in those programs. But, but so what's a 40, you know, what's what given example of a program that is funded using $40. You said that some of this, some of some of some of the resident that the comment was that not all of our residential programs are funded. So Park Street, for example, so Howard Center, which is part of Chittenden County designated mental health agency has a program called Park Street that provides residential care for youth with sexually harmful behaviors. And that is for we currently draw down for a for all of the youth in DCF custody placed in that residential program. And as of October 1, we will no longer be able to draw down that 40, unless they become a qualified residential treatment program, and these other pieces. And that's where the one point something. That's right. That's where we're going to come from. The benefit of these that I've heard the purpose or the benefit of this federal shift is at this time is to put more money into prevention, whatever, and if I recall, prevention is something that individual states define how they will define prevention, whether it is primary prevention, or whether it is preventing to come into placement. Please correct me if my record. For the, for the purposes of the Family First Prevention Services Act, it is specific to tertiary prevention, meaning they are talking about preventing children or youth from coming into DCF custody. The actual federal language is candidates for foster care. So what they consider to be we are preventing children from becoming in foster care. Which are our local district offices have different, you know, they have the, they have the source. The case managers work with kids who are in custody. And in. And some of those kids in custody are still living at home. And some are at this are not. I mean, and some are sort of protective service, I forget what you call those. Right, we have a population of cases where we actually have what we call family support caseload, which is children and youth that are in a household that has that has been assessed to be high or very high risk of child abuse or neglect occurring again in that home. And you're exactly right and that is the target population. So when we submit our ffps a prevention plan. We will be saying the families that are on the family support caseload are what we consider to be candidates for foster care as evidenced by our structure decision making tool that demonstrates that they're high risk. And the other population is children that are in the conditional custody of their parents. So we've had a chins process they've they've been, there's been concerns protection concern and there's been a court order that certain pieces need to be followed like substance use treatment, but they remain in the home. That's our second target population. How is that paid for now. How is some of the, you know, how is the those those to the tertiary paid for now I mean do we use for can we use for refunds is it general funds. Is it MCO is it TANF funds. What is what it. So and Sarah can certainly help me out here but we do draw down some for refunds for our employees salaries. So we do we do look at what is the work that the family services workers are doing and we're able to draw down for me for some of that work. And then for the children that are in DCF custody and paid placement, we're able to draw down additional for a funds for that. So for the family support cases for the staff that support that caseload the majority of their salary is pulling from general fund but there is some cost allocation to other sources. But it's all governed by the work in the caseload that they do with the with the majority of the salary pulling to general fund and the cost allocation. Okay, so, so, and sorry it's on my mind. So that there's, there's no TANF funds used the TANF report shifts based on how we draw it down. It's not one that comes to my mind as a main driver but I, I'd have to look at exactly how our cost allocating based on the last quarter to give you a definitive what the federal funding sources are behind it. If that's not there, that's fine. Thanks. I'll ask it another day. And we can certainly get that for you into in the committee because it is complicated and it's ever changing, you know, based on the cases and the work of the staff so. We're actually in the process of running finalizing our reports right now so if you like I'm happy to share them with you once they're finalized of what that breakout looks like for this quarter. Thank you as we, whether it's to the committee as a whole or whether it's to the, what I call the work group, which will be looking at that part of the budget, we will do that. But I realized as we were talking and I should know better. But Chins, what is Chins. I mean, I know what it is but we are using, you know, we're using a lot of anachronisms, whatever. I apologize for my acronyms. So chin stands for child in need of Karen supervision. So that's the language in state statute that governs when a child comes into, well comes to the attention of the court as a child in need of Karen supervision and it's through that process that a child would potentially be ordered into the custody of the commissioner of the department. So that's the committee, given this sort of initiative that we as a legislator need to be sort of paying attention to, as well as some legislation that the department would like us to look at. I need a quick, not today, and whether, whether it is from you all commissioner or whether we have ledge counsel, probably a review of the child protection process. And that might be helpful to all of us in terms of moving forward. I have let the committee know that I will be introducing a bill on behalf of the department around the registry review. And, you know, there may be. And, and many of us on that on the committee is our will be introducing a bill related to the child advocate. We have this. And I guess I've given the fact that we're a little behind the little behind lots of good reasons, but we're a little behind in terms of moving forward and terms of the Family First Prevention Act. I think it will for us to do our due diligence we're going to keep asking you to come in and asking questions so that to help you move forward. Yes, I, I'm happy to spend more time with the committee and provide whatever information you deem useful. Absolutely. And we can have Brenda's team come in and give an overview of the child protection system because it is complicated. Any, if do commissioner to you or any of your staff have a fine want to leave us with a final comment, I do not see any more questions. Yeah, I want I just think the committee for your time today. We're going to approach the implementation of this very thoughtfully with the, you know, what's going to be best for remote families and kids. You know, in terms of the programs we develop in the services we provide, and are able to enhance or leverage with this funding, you know the financial pieces the financial piece and we will figure that out. At the end of the day, you know this, you know the intent of this is to really put a focus on prevention and I think that's what's going to be in the best interest of Vermont families and kids is prevention and you know that's our goal here is to implement this with that first and foremost in our mind is how do we best serve Vermont's kids to make sure they're safe and are able to stay in with their with their biological parents and their home. Well, thank you. Thank you very much. And committee, do you have any further question of the commissioner. We do have one. Thank you. I don't mean to sound so surprised. I'm ready to ask my question. As far as, and thank you, Commissioner and Brenda and Sarah so much for presenting. I'm definitely learning a lot. So thank you. My question has to do with the, the qr TPs and how do you have a sense of how many of them are ready or open to create this transition to becoming certified commissioner Brown mentioned that some might not reach that point. But I think we're going to do to limitations. And because it sounds like we're making some pretty, there's also some pretty big, you know, systematic requirements, as far as our judicial system, and things like that, and to just think that both the state and the providers will be taking this on together. I guess, have you started that sort of outreach process engaged how how ready they are to make these changes. Yes, and that is so that is the work that our residential licensing and special investigation unit is doing is meeting with them. And I think generally speaking they're open to it but it costs money. And so that's part of the, you know, the work ahead is to figure out, you know, what efforts can be combined, you know, such as the nursing care and maybe they could enter into, you know, a multi agency agreement around certain, you know, certain systems. So having the after care, being more trauma informed. I think that these are principles that people are really aligned with, but for some of the smaller programs, it can be really challenging financially to think about how to get there. So, you know, that's, I think part of the process that we're, we're part of our readiness assessment. Thank you. I was going to wait till later some other time to ask this question but since it sort of just came up. Brenda on the financial side of things, I guess I'm trying to figure out. So if our programs come into compliance with these things. And that make us eligible for additional when that make that eligible for an increase in their rates additional additional payment to offset those increasing costs since that they are requirements. So becoming a qrtp is part of it but then we also would need to have the judicial review in place and the clinical review in place. So all those different pieces need to be in place for us to be able to draw down those for funds. And then it becomes, you know, what is the rate of reimbursement the daily rate for each youth who's placed in that program that the program receives. And, you know, so that would be I think part of part of the work ahead is figuring out, you know, what is the rate that each program should receive moving forward. Yeah, and I would just point out that the first 14 days of each residential placement are still for eligible to the youth remains in that program. Beyond that, that we will not be able to draw for E dollars down unless we meet those judicial reviews to clinical reviews and and all of those other pieces within that 60 day period as well. Thank you. Representative on. Thank you madam chair. My question is, is the New Hampshire company that we're using now a qualified residential treatment program. I'm sorry I was just noting, should I be turning off live stream. No. We're still, we're still. I'm getting consultation. I apologize I missed your question because I was distracted by that. Well, I've. Representative McFawn asked if the back it who runs program serving remote youth we have this, you know, the youth in the new in New Hampshire and their programs but also, they run the Vermont school for girls. And so, Representative McFawn was asking are they are they qualified residential treatment program at this time, or meet the requirements of that. They're not already they're very close. I mean they're definitely way ahead of other programs they were very clear from the beginning that they were going to become a qrtp because they're serving so many states. So I don't know officially if they are right now, but I know that they're almost all the pieces in place that needed to be in place are there for for Beckett. So, when we finish putting the money into their, their facility in Newbury. I'm hoping that they will be accredited by them, if they're not now. I believe because the Newbury site. The covered bridges is a locked facility I don't know that that is actually able to be a qrtp. I think the nature of the population served in that setting is not not a program that that could draw down those funds. Okay. Thank you. We did explore that in the funding of that program and it is an eligible for for e based on the population that it serves and the regulations around drawing down those funds. Okay, thank you. Thank you. And clearly, we're going to have lots of conversation about all of these issues. And, but I think we have probably come to the conclusion today, in terms of where we are. And committee, I will see you all tomorrow. 15 minutes when we get off the floor, when again. When again, we can see you commissioner. And Brenda, I believe you and I are co host of this meeting. But since you. So I am going to close this meet if you as co host, are you co host or the primary host. I know I am at least a host, if not a co host. Okay, that if you are the host as opposed to a co host. This will end our committee meeting today. And as we turn off we will be leaving YouTube as well.