On Thursday, July 18, 2019 the Children’s Bureau released guidance to states on how they can include in their state plans procedures to allow for “transitional payments” for prevention services and programs that have not yet been listed in the Family First Prevention Services Clearinghouse. Program Instruction ACYF-CB-PI-19-06: says that the instruction allows a state to claim transitional payments for services and associated costs under the title IV-E prevention program until the Clearinghouse can review and rate a program or service, if a state submits the appropriation documentation by October 1, 2021. While the Clearinghouse will have the final say but this process will support the Bureau’s goal to review programs and services as quickly as possible in the early years of implementation of the new law. States have the option for services funding starting October 1, 2019.
A state must complete and submit a checklist, Attachment B Checklist for Program or Service Designation for HHS Consideration, with all required documentation, to request transitional payments for a title IV-E prevention program or service which has not yet been rated by the Clearinghouse. The state must submit the checklist as part of their five-year plan, or as an amendment to an approved five-year plan by October 1, 2021. If that states receives approval to go ahead then other states may submit a five-year plan for approval for those same programs or services, but must submit the plan or amendment by October 1, 2021. The PI also specifies:
• Once the Clearinghouse rates a program or service with the same or higher designation as the designation approved as part of the state title IV-E plan, the Clearinghouse rating becomes effective and the state may continue to claim title IV-E prevention services and associated costs.
• If the Clearinghouse does not rate a program or service as meeting the promising, supported, or well-supported criteria, HHS will make transitional payments for such services (and associated costs) provided only through the end of the Federal fiscal quarter following the Federal fiscal quarter in which the Clearinghouse rating was assigned.
• If the Clearinghouse rates a program or service with a lower designation than the designation approved as part of the state title IV-E plan, the transitional payments designation will remain in effect through the end of the Federal fiscal quarter following the Federal fiscal quarter in which the Clearinghouse rating was assigned.
A Federal Fiscal quarter is October-December, January-March, April-June, and July-September. So once the Clearinghouse doesn’t rate a program or a program is rated lower, payments will continue potentially for up to just under six months or just over 3 months.
The Attachment B Checklist includes a three page checklist of items states must include, and seven pages outlining the study design and execution and additional information including effects of the program being evaluated.