Some critics of the Families First Prevention Services Act have recently argued that the proposed bill does not truly provide prevention services.  In part this depends on how the individual defines prevention.

CWLA views the Families First Act as providing an important part of the child welfare continuum, intervention services that can prevent placement into out-of-home-care/foster care.  These prevention of foster care services would be available to birth parents, kin parents dealing with the potential trauma a grandchild or other relative children may face, families that have just been reunified or adoptive families who may face the need for post-adoption services years after the adoption was finalized.

We see prevention of child maltreatment or child abuse as another separate and critically important part of that continuum.  Both prevention and intervention are vastly underfunded and all too often some advocates will play one of these two key parts of the continuum off the other.

CWLA highlighted this need in our April Summit:  Investing in What It takes: A Full Continuum of Care. As we noted in that gathering:

 “we need NEW investments in children starting with preventing child abuse, preventing foster care when possible and providing the best care when necessary, and ensuring permanency and safety for all children through reunification, kinship care and adoption.”

The Families First Act, if effectively implemented, would provide critical intervention services for mental health and substance use and in home services that have been frequently lacking.  The fact that mental health and substance use treatment services could be available through Medicaid does not mean they are available.  Coordination and cooperation between Medicaid and child welfare have been a challenge to say the very least.  The Families First bill would provide a new avenue for these services to address substance abuse and mental health treatment needs that by some estimates are a part of anywhere from 30 to more than 60 percent of child welfare and foster care placements.

We see prevention of child abuse as an equally important component of the child welfare continuum of care.  One of the challenges in amending Title IV-E to address true prevention is to develop an effective trigger to access federal funding that would both allow funding of effective programs while not allowing access to federal funds to be used to plug state budget demands.  A trigger that would be contingent on any report of child abuse or any family that comes to the attention of child welfare as a trigger is a low threshold to access federal entitlement funding and it would never pass Congress because of the potential abuses.  Such open ended funding is what led to a Democratic Congress in the early 1970s to place hard spending caps on the open-ended Social Services entitlement funding during the Nixon administration.  It fed into arguments to convert that federal funding source into the fixed Social Services Block Grant in 1981.

Prevention is critical but in addition to the challenge of developing an appropriate use of IV-E funds for prevention, too few advocates have highlighted the need for greater funding for the Child Abuse Prevention and Treatment Act (CAPTA) which is stuck at less than $26 million for all fifty states. Similarly, the Community-Based Child Abuse Prevention (CB-CAP) grants which fund prevention initiatives and that leverages private and non-government funding to provide community based services to prevent child maltreatment funding is stuck at $39 million.

The need for more prevention also highlights CWLA support and the need for a significant increase in funding for the evidence-based home visiting (MIECHV) program when it is reauthorized in the next Administration and Congress.  Prevention also means needing to address the very serious underfunding of child care (CCDBG), and Head Start.

The need for more funding for the prevention of child abuse should not undercut support for an increase in funding for the intervention/prevention funding to reduce some foster care placements.  They are both part of the continuum of child welfare services.