Now that the House Republicans have introduced a reauthorization of the MIECHV (Maternal Infant Early Childhood Home Visiting), or home visiting program there are a number of concerns with the current legislative draft.
The Increasing Opportunity through Evidence-Based Home Visiting Act (HR 2824), while it would extend the program for five year as CWLA and other advocates have proposed, it provides level funding of $400 million a year instead of the gradual doubling of funding over the course of the five-year reauthorization. There are many issues of concerns with the bill but it does extend an important program for five years.
The Home Visiting Coalition (which CWLA belongs to), is applauding the action to reauthorize the program, but continues to advocate for $800 million increased over a five-year reauthorization. In addition, other, key concerns raised by the Coalition:
- Funding Level: MIECHV is one of several mandatory, non-defense programs that are subject to sequestration. In FY2017, MIECHV funding was cut by 6.9 percent, resulting in a nearly $26 million loss in funding for the program. If this program is level funded, sequestration, coupled with the effects of inflation, will greatly affect the ability of MIECHV to improve outcomes for families in need.
- New Evidentiary Tier: MIECHV enjoys the distinction of being among a select group of evidence-based programs with a rigorous evidentiary standard. Except for promising programs, home visiting models desiring to participate in MIECHV must demonstrate their effectiveness by meeting certain outcomes through high-quality quasi-experimental designs or randomized controlled trials. In fact, many of the home visiting models participating in the MIECHV program have decades of scientific and real-world experience pointing to the fact that achieve one or more of the benchmark outcomes that has become the hallmark of the MIECHV program. MIECHV requires states to meet or exceed benchmarks that correspond to important child and family outcomes. MIECHV’s strong evidentiary standard has been credited for incentivizing private/public partnerships to foster greater investments in MIECHV. Given that MIECHV is among the programs considered the gold standard with respect to its evidentiary standard, we question the need for yet another evidentiary tier with even more stringent requirements, particularly in the absence of the national evaluation demonstrating the need for stronger evidentiary standards.
- Matching Requirement: While the Coalition appreciates the fact that the legislation allows states to match MIECHV funding with funding from other federal programs, we note that the phased-in dollar-for-dollar match will create the potential for significant instability in programs and communities at risk of losing MIECHV-funded services if certain states cannot meet the state match. We are concerned that some poorer states or states without a long history of the ability to invest in home visiting may be forced to reject MIECHV funding as a result of the match. We are concerned that certain states who fund other state and federal early childhood programs, such as Georgia who funds statewide preschool, will be in jeopardy of losing MIECHV funding solely as a result of their desire to concentrate state funding in other equally-important initiatives for children and families. We are also concerned about the programs eligible for the state match. For example, should Congress significantly cut Medicaid or impose per capita caps, states would face difficulty satisfying the match with Medicaid funding.
- State Needs Assessment: The Coalition has questions regarding the manner in which the needs assessment will be required and used. For example, we question what states are expected to do with an updated needs assessment in an environment where there is no additional funding. We do not want states to defund current programs in needy communities to implement programs in even higher risk communities. Such a scenario does not fulfill the need to expand services to more children and families in disadvantaged communities. We note a new provision in the legislation that allows states to consider community resources when selecting high-needs communities to implement programs. Many disadvantaged communities lack resources, particularly rural and tribal communities that lack health care providers and other resources. We are concerned that states could inadvertently cherry-pick communities to avoid the highest-risk, highest-needs communities simply because they lack resources. This could have a particularly negative impact on rural and tribal areas. The flexibility in MIECHV already allows states to match a community’s needs and resources with an appropriate home visiting model. We look forward to learning more about this provision and working with members of Congress to maintain MIECHV’s goal of serving the hardest-to-reach.
- Economic Self-Sufficiency: We have concerns that the additional language to the family economic self- sufficiency benchmark contradicts the benchmark that pertains to improvements in the coordination and referrals to other community resources and supports. Home visitors are trained to support families through mentoring, education, and when appropriate, referrals for additional assistance like mental health services or job training. The new language undermines the efforts of home visitors to help improve family stability by leveraging already-existing community resources. Additionally, collecting data on these measures will make development of a trusted relationship between the home visitor and parent harder to achieve, ultimately limiting the core outcomes the home visiting program was designed to achieve.
- Pay-For-Success: The Coalition supports innovative financing mechanisms that allow more children and families to receive home visiting services. However, the bill’s provisions would allow states to devote its entire MIECHV allocation to pay-for-success initiatives, which could conceivably reduce, eliminate or create extended gaps in services to children and families. If the Committee is interested in using pay-for-success as a financing source, that should be in addition to current funding levels.
- Pay-for: Control Unlawful Fugitive Felon (CUFF) Act: the Coalition has serious reservations about this pay-for, which would deprive individuals who were not convicted of a crime from receiving Social Security disability or retirement payments to which they would otherwise be entitled.