CWLA submitted its recommendations and comments in response to the HHS request for comments on how to approach the issue of defining and listing services and programs that will qualify under the Family First Prevention Services Act. There was a very quick turn-around time with comments due by July 22.

CWLA emphasized the need to be expansive in what should be included in an October list of services and programs for use under the Family First Prevention Services Act. We paid special attention to specifically targeted categories covered by the law–kinship navigator and teen pregnancy prevention programs. CWLA raised the need to allow for combining services when it comes to serving families. This can be especially critical in post-adoption and reunification services that may require a combination of in-home and mental health services.

CWLA called on HHS to rely on the approved programs and reviews that have be utilized in other HHS programs including the home visiting, teen pregnancy prevention and SAMSHA reviewed services and programs.

HHS is to release the criteria and an initial list of approved services and programs allowed under Title IV-E by October 1, 2018 for use by October 1, 2019. Funding is not dependent on an annual congressional appropriation or an income limit on the family.