On Monday, November 1, 2021, the Child Welfare League of America submitted its recommendations to the Senate Finance Committee on how the Committee and country can make critical changes to the nation’s mental health and substance use treatment systems. The Committee had asked the behavioral health community and other parties to submit recommendation to the Committee by November 1, 2021 (the date was extended).

The CWLA letter stated that addressing mental health services is a significant need and challenge within child welfare (including child protection).  It points out that primary prevention efforts, family preservation, reunification, adoption, and all forms of permanence requires addressing barriers created by behavioral health needs.

The tone of the letter is how vital it is for the behavioral health system of mental health and substance use to helping families, pointing out that, child welfare and juvenile justice, “were not created to provide vital behavioral health services and it is inevitable they will be held accountable for the failures in the provision and quality of any treatment. In addition, families struggling with these issues should not have to turn to these systems as their only option to accessing critical services.”  The letter highlights past evidence that some families have turned to these two systems in a desperate attempt to get the services they need for their children because they don’t have another point of access.

The CWLA recommendations highlight the need for greater attention to maternal health, the needs of adolescents and youth, Medicaid reforms, telehealth improvements, enforcement of the 2008 parity law, the workforce within behavioral health and the need to strengthen substance use treatment.

Under Medicaid reforms, CWLA calls on Congress to better align some laws and guidance that cause unnecessary access barriers to needed services such as the ongoing mixed interpretations of how therapeutic foster/family care is covered (or not) under Medicaid and calls on the Committee to straighten out the current lack of coordination between the “IMD” law and how it applies or potentially upends use of the new Title IV-E QRTP residential treatment standards.

Under substance use treatment CWLA suggests the Committee reassess the Regional Partnership Grants (RPGs) which have provided competitive grants from a small block grant of $20 million. The funding created in 2006, originally targeted methamphetamines which disproportionately assisted white rural areas. It is not large enough to cover all fifty states or all areas within a state.

The letter, from President and CEO Christine James-Brown concludes with, “Effective mental health and substance use services will reduce the number of children and families that come to the attention of child protection or child welfare. We appreciate the committee’s outreach, and we look forward to continuing our efforts to help you address this problem in a strong bipartisan manner.”