On November 16, the Children’s Bureau issued ACYF-CB-IM-18-05, a memorandum on primary prevention, and “to strongly encourage all child welfare agencies and Children’s Bureau (CB) grantees to work together with the courts and other appropriate public and private agencies and partners to plan, implement and maintain integrated primary prevention networks and approaches to strengthen families and prevent maltreatment and the unnecessary removal of children from their families.”

The IM signed by Jerry Milner emphasizes an important theme that Commissioner Milner has repeated since coming into office, preventing child abuse and neglect before it happens and before the family is at risk of a foster care placement. In the past he has touted the Administration’s 2019 budget proposal that would allowed a waiver of Title IV-E foster care funds as a way to fund primary prevention. He discussed the proposal at the April 2018 CWLA National Conference and suggested that the key feature was the flexibility of funding as a way to fund such services.

The IM also states:

“coordinated and robust primary prevention efforts are critically important to strengthen families, prevent the initial occurrence of and ongoing maltreatment, prevent unnecessary family disruption, reduce family and child trauma, interrupt intergenerational cycles of maltreatment, and build a well-functioning child welfare system…Children’s Bureau’s top priority is to reshape child welfare in the United States to focus on proactively strengthening families through primary prevention of child maltreatment. To accomplish this, CB believes strongly that primary prevention services must be located in communities where families live, where they are easily accessible, and culturally responsive. Those services should also focus on the overall health and well-being of both children and families and be designed to promote resiliency and parenting capacity.”

The memo represents a resource in terms of prevention programs highlighted from across the country. The IM notes that common problems of limited or loss of income, inadequate housing, or civil legal issues, if left unattended, can escalate to crisis and lead to formal child welfare system involvement. Neglect was present at the time of removal for over 60 percent of children who entered foster care in 2016 and substance abuse was present in approximately one third of families, with the inability to cope by a parent(s) present for 14 percent of children that entered care. Those numbers are likely low since they are frequently based on a caseworker’s first observation and many families may have multiple challenges in which substance use is just one of many challenges.

The Bureau memo notes the need to address the protective factors in a family’s life and how the erosion of such factors can push families into the child welfare or CPS systems.

“While some families may benefit from an evidence-based clinical intervention, many families…would benefit from a temporary boost, someone to listen and provide good counsel, or very basic concrete supports such as help paying rent or a security deposit for housing, child care, transportation, legal services, or brief periods of respite care to allow parents time to seek help and work through a challenging situation. These types of services and supports coupled with efforts to enhance parenting skills, promote healthy child development, build and maintain positive peer and relational support networks, and help families achieve financial self-sufficiency, before crises arise, are all critical primary prevention efforts that can help prevent bad things from happening in the lives of children and parents.”

The memo encourages state and local child welfare agencies to work together with other key community partners and resources. They also highlight the need to coordinate and work with legal systems including judges. The IM provides eight examples of community-based efforts from Allegheny County, Pennsylvania to San Francisco California and how these community-based efforts built up partnerships to provide an array of supports and services to families.

Financing
The issue of how to finance primary prevention is likely to come up in the 116th Congress. With an initial list of services now published by HHS there is likely to be more discussion of how to adapt current waiver funding to the services available both the services listed now and what is listed next year. As states work to implement the Family First Act, several states and counties led by Ohio and Los Angeles County will be arguing for an extension of waivers due to expire next year. They have argued it is the one way to address primary prevention. The 2016 Child Trends Report and survey of state child welfare systems indicated that the overwhelming majority of state waiver funds have been spent on Title IV-E programs and not prevention. Waivers due have the benefit of relieving administrative burden tied to determining eligibility per child.

Generally speaking when states have flexibility in federal funds, they still spend a significant amount on foster care and not prevention (some would suggest that is because the system of child welfare services is simply underfunded from prevention through placement). The flexible funds of Child Welfare Services, Title IV-B, SSBG and TANF all have spending allocated by states on foster care. In the 2017 Child Welfare Service Plan 18 states indicated they would spend $25 million of the total $269 million in funds on foster care maintenance payments. The last SSBG annual report (2015) indicated that 33 states used $118 million of SSBG dollars and $308 million of TANF funds transferred into SSBG for foster care. All these funding sources could be used for flexible community-based prevention/waiver funds. Like many block grants their value has been reduced by inflation and across-the-board budget cuts. They frequently lack political support by advocates and states alike.

Funding Primary Prevention—That Isn’t a Waiver
CAPTA
The Child Abuse Prevention and Treatment Act (CAPTA) could serve as the primary prevention program if there is the political will to increase funding. CAPTA (which has included the word prevention since its creation in 1974) has two vital funding mechanisms: CAPTA state grants and Title II Community-Based Child Abuse Prevention (CB-CAP) grants. State grants received an historic increase in 2018-19 going from $25 million to $85 million. To become more than just a child protection services funder it needs significantly more funding.

CB-CAP which is found under Title II of the authorization has been stuck at $39 million for several years. It funds community-based primary prevention programs and efforts, but it too needs a significant increase in FY 2020 and for several years after if it were to ramp up primary prevention.

Then there is the shrinking role of TANF. It has lost more than 35 percent of its value due to inflation. Whereas it covered 68 percent of poor families in 1996 it now covers less than one in four. It also has drifted from becoming a cash assistance program that has as its number one purpose as written into law: “provide assistance to needy families so that children may be cared for in their own homes or in the homes of relatives.” While it has always been a source of limited support for some kinship families, the shrinking funds have the potential of pitting a family in need of cash assistance against a relative caregiver who may have come to that role because a stressed family was pushed over the financial edge when they were denied TANF. It begs for a reauthorization of TANF that goes beyond percentage of adults meeting a work requirement and that boosts funding and refocuses it mission including supporting families. Re-reading the Children’s Bureau IM:

“While some families may benefit from an evidence-based clinical intervention, many families…would benefit from a temporary boost, someone to listen and provide good counsel, or very basic concrete supports such as help paying rent or a security deposit for housing, child care, transportation, legal services, or brief periods of respite care to allow parents time to seek help and work through a challenging situation. These types of services and supports coupled with efforts to enhance parenting skills, promote healthy child development, build and maintain positive peer and relational support networks, and help families achieve financial self-sufficiency, before crises arise, are all critical primary prevention efforts that can help prevent bad things from happening in the lives of children and parents.”

TANF was created to provide increased flexibility to states so it could do many of those interventions and by doing so strengthen families and keep families together.

About the Author:

John Sciamanna is CWLA's Vice President of Public Policy.

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