The California Department of Social Services (CDSS) has recently provided guidance and instructions regarding Interagency Placement Committees (IPCs), Short-Term Residential Therapeutic Programs Placement (STRTP) Criteria, Child and Family Teams (CFTs), and Second Level Review requirements for children and nonminor dependents placed in STRTPs and group homes.
Assembly Bill 403 established new licensed children’s residential facilities called STRTPs, which are public agencies or private organizations licensed with CDSS to provide integrated, high-quality, therapeutic programs. The programs are intended for children whose behavioral and therapeutic need are not met by a home-based family setting, even with supportive services. The goal of the program is to provide trauma-informed therapeutic interventions and integrated programming to address barriers to the child’s ability to safely reside and transition into a home-based family setting. The county placing agency, the STRTP, the caregiver, and the child and their support system must work together to identify and coordinate necessary services.
STRTP homes must be cleared by IPCs and a second level of review which takes into account CFT’s opinions.
The IPC is made up of representatives from county placing agencies and the county Mental Health Plan (MHP). The IPC may work together with other jurisdictions to act as a multi-disciplinary committee for child care and treatment. The IPC must also review and approve placements for STRTPs, group homes with a level of care assessed at Rate Classification Level 13/14 and that have been granted extensions (as determined by ACL 16-65), as well as out-of-state residential programs. The IPC decision is to be made by reviewing all available assessments. To support partner agency compliance, county placing agencies must notify and coordinate needed services with the school of origin regarding educational stability and the case plan, the MHP, and the Regional Center currently serving the child immediately upon the child’s placement.
The child may be placed in a STRTP if the child does not require inpatient care in a licensed health facility and the child’s needs have been assessed and can be provided in a STRTP to maintain the health and well-being of the child. One of the following criteria must also be met:
- the child meets medical necessity criteria as determined by a mental health professional
- the child is assessed as Seriously Emotionally Disturbed
- the child is assessed as requiring the level of services provided by the STRTP
- OR the child meets the criteria for emergency placement into a STRTP.
Emergency placement determinations may be made prior to the IPC determination if:
- A mental health professional has made a written determination that the child requires the level of care that STRTP services offer
- The IPC makes a similar determination within thirty days of an emergency placement (or transmits their disapproval to the STRTP)
- AND the STRTP is not acting as a temporary placement in the event that a home-based family setting cannot be found. The county placing agency must ensure there is commonality of need with the other children in the placement setting.
If counties decide to integrate the CFT and IPC into single meetings, they should do so via an Interagency Memorandum of Understanding.
STRTP providers are not required to accept any specific child for placement, though they are expected to have the capacity to serve individual children with complex needs. The intake process should be coordinated with the IPC to avoid non-admissions and 7-day notices of denial from an STRTP provider, and information should be conveyed to county placing agencies to allow for CFT meetings pending placement. If STRTP providers demonstrate a pattern of not accepting placements, a review may be conducted by CDSS to assess the technical assistance level of the STRTP in order to prevent unnecessary disruption.
Assembly Bill 1997 provided added requirements, and also requires that the Department of Health Care Services and CDSS develop a dispute resolution process in order to track the number of reported and resolved disputes. While this is developed, county placing agencies should inform the CDSS if there is an unresolved IPC dispute by emailing CDSS.
The Continuum of Care Reform (CCR) uses residential care as a short-term, therapeutic intervention until the child is able to transition into a home-based family setting. The CCR includes additional requirements on case plan documentation and second level review. The former requires that the case plan for a child placed in a STRTP document that the placement is for the purposes of short-term, specialized and intensive treatment, the need for the placement, the plan for transitioning the child, and the projected timeline for future action. If the child is under 12 years of age of younger, prior approval from the director of the child welfare agency is needed.
The Placement Timeframes for Second Level Reviews are age-specific. For children ages 0-6, STRTP placements are extremely rare and not to exceed 120 days. For children ages 6-12, STRTP placements shall not exceed 6 months unless the county made progress toward implementation of the case plan (including the child’s future transition), circumstances beyond the county’s control have impeded the county from obtaining those services, and the need for additional time is documented by a caseworker and approved by the Child Welfare Deputy Director. For children older than age 13 under the supervision of the dependency court, the placement shall not exceed 6 months unless the Child Welfare Deputy Director or Director has approved the case plan. For children older than age 13 under the supervision of the delinquency court, the placement shall not exceed 12 months unless the Chief Probation Officer of the county has approved the continued placement no less frequently than every 12 months thereafter.
County placing agencies should have established processed to ensure that these processes are followed immediately for children placed in STRTPs or group homes. (ACL 17-122, January 9, 2018.)