A June 6, 2019 letter from Children’s Bureau Commissioner Jerry Milner to child welfare leaders indicates some broader flexibility in funding Family First Prevention Services in the initial implementation. The key part of the letter is the last paragraph where Commissioner Milner states:
“Therefore, the CB plans to issue guidance allowing 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 sufficient documentation. The guidance will specify what documentation the state must submit to demonstrate that the state conducted the independent systematic review and met the criteria outlined in section 471(e)(4)(C) of the Act and Attachment C to ACYF-CB-PI-18-09. While the guidance will allow for transitional payments, the Clearinghouse will ultimately make the final determination about whether a program or service is assigned a promising, supported, or well-supported rating. While I cannot provide more details in this letter, I hope to share this guidance with you in the coming weeks.”
The statute and the Family First Transition and Support Act (HR 2702/S 1376) clarifies that states may submit their programs for inclusion in their services plan under Family First Act if the state-implemented programs meet the evidence standards written into the Family First Act. What the Milner letter seems to indicate is that in the initial stages states may be able to use these programs even if not included on the Clearinghouse list and the state will be reimbursed. Eventually that reimbursement may not continue in a later date or plan if it fails to gain the official blessing of the Clearinghouse.