California’s Family First Prevention Services (FFPSA Part I) – Frequently Asked Questions (updated October 6, 2023)

Yes. The SBG can be used to support participation of foster youth and/or persons with lived experience in the cross-sector collaboration process, such as participation in planning activities and ongoing CQI activities. Training or administration claiming codes may be used based upon the individual’s specific form of participation. Please see CFL 21/22-84 for additional information.

As detailed in ACL NO. 22-23, the State Block Grant is a one-time appropriation that must be spent over three State fiscal years, ending in fiscal year 2024, however, CDSS will pursue options including putting forth a request for additional time to expend funding.

Opt out instructions can be found in ACL 23-23 (Page four) and the Opt Out template (Attachment I) may be used to complete the opt out process. The template requires signatures from child welfare, probation, and behavioral health. The completed template may be submitted to the CDSS Prevention Inbox at ffpsapreventionservices@dss.ca.gov.

To access funds immediately, counties must submit a completed LOI to inform the CDSS of their early intent to opt into the FFPS program. If a county doesn’t submit a LOI, they can still access SBG funds once CDSS provides approval of their CPP. Once a County opts in, they can begin accessing SBG funds under the FFPS program. The SBG funding is available and intended to support the development and implementation of the local CPP. Allowable activities for SBG funding include administrative activities to support the delivery of FFPS services, expand FFPS capacity, support evaluation, training, and measure FFPS readiness.

Counties that elect to not participate and receive FFPS SBG funding early may opt in later by submitting a CPP. Counties should develop and submit to CDSS a CPP no later than July 31, 2023, to continue or begin accessing funding under the FFPS program. For additional information on the CPP and opt-in process please review ACL NO. 22-23 and ACL 23-23.

No. A capacity and readiness assessment are not required components of the CPP although inclusion of a capacity and readiness assessment is strongly encouraged to assist the understanding of community needs and the capacity for system changes needed for implementation. However, Asset Mapping and Needs Assessments are both required components of the local CPP, as listed in ACL NO. 22-23.

The ten (10) EBPs chosen for California’s 5-year prevention plan are all well- supported EBPs in the Title IV-E Prevention Services Clearinghouse. As such, CDSS is requesting a waiver of the evaluation requirement for each of these EBPs statewide, which was submitted to and approved by ACF along with the Prevention Plan.

Yes, although local CPPs must include EBPs listed in the State’s Five- Year Title IV-E prevention plan, counties may also choose to include additional EBPs not listed in the Plan as part of a continuum of comprehensive prevention services.

Yes. ACL NO. 22-23, details allowable activities under the State Block Grant (SBG) funding, which include primary prevention services. Primary prevention is defined as, “activities are directed at the general population to strengthen communities and improve child well-being by focusing on the social determinants of health, defined as the conditions into which people are born, grow, work, live, and age, and the wider set of forces and systems shaping the conditions of daily life.” Therefore, a guaranteed income program developed to strengthen communities and improve child well-being could be considered primary prevention services. The local GI program developed as a prevention service and its expenditures should be detailed in the CPP.

For information on or requests to exempt income of a local GI program from Cal Fresh or Cal Works benefits budgets, please contact IncomeExemptionRequest@dss.ca.gov.

Yes, the child welfare agency can opt in as the lead agency. However, comprehensive prevention planning should include cross sector collaboration. As such, the probation department should remain as part of the comprehensive prevention planning process.

If the child welfare agency has determined that they will not participate as the lead agency, the probation department can serve as the county’s lead agency for comprehensive prevention planning.

Probation departments that serve as the lead agency for purposes of submitting the CPP must ensure that they remain in consultation with other relevant county agencies that serve families and children, Indian Tribes, local community representatives, caseworkers, and individuals with lived experience with the child welfare system as well as comply with the requirements and deadlines of the FFPS Program.

The CDSS will provide additional technical assistance and support to probation departments who are designated as lead for the CPP to ensure that all requirements are met.

Counties must include, at minimum, the funding strategy for how each service, within the plan, will be paid for. The funding strategy should describe the extent to which SBG, Title IV-E, and other leveraged funds are used. The use of the spending plan template developed by CDSS is optional. If partial completion of the State’s optional template includes this minimum information, then it may fulfill the requirements of the spending plan. As stated in ACL NO. 22-23, the CPP requires “Inclusion of the local Title IV-E agency’s spending plan, which describes how the State FFPS Program Block Grant will be used for prevention activities and services, and the extent to which additional funds are leveraged for comprehensive planning.” The FFPS Prevention Funding Guide provides guidance to assist with strategic financial planning and implementation of the Family First Prevention Services (FFPS) program, as well as the development of the Comprehensive Prevention Plan (CPP) components.

The CDSS encourages counties to leverage stakeholder meetings and focus groups to meet the needs of both the C-CFSR and the development of the CPP provided the requirements of both programs are met. While there are commonalities between the development of the CPP and the C-CFSR process, counties must consider that the requirements and objectives for both initiatives are different, and the requirements of both programs must still be met.

Title IV-E agencies that submitted a Letter of Intent (LOI) opting in to receive State FFPS SBG Grant Funds were eligible to begin submitting retroactive claims as of October 21, 2021. Agencies that did not submit an early intent to opt in do not have early access to SBG allocation and are not eligible to submit retroactive claims until they have submitted and received approval of their CPP. Please refer to CFL No. 21-22-110 for additional information.

It depends. For Title IV-E purposes, California defines “child” as a child up to age 21 in the foster care program, and some youth between 18 and 21 may be eligible for the title IV-E prevention program. As described in federal Program Instructions on page seven of ACYF-CB-PI-18-09:

“the definition of ‘child’ in section 475(8) of the Act applies to the title IV-E prevention program. Therefore, both a “child who is a candidate for foster care” and a child who is a pregnant or parenting foster youth must meet the definition of “child” as elected by the state for the title IV-E program to be eligible for the title IV-E prevention program (section 471(e)(4)(A)(i) and (ii) of the Act). This means that a “child who is a candidate for foster care” and pregnant or parenting foster youth who have not attained age 18 are eligible for the title IV-E prevention program. If a state has elected a higher age under the state’s title IV-E program, an otherwise eligible youth over age 18 may be eligible for the title IV-E prevention program in the following circumstances:

• • If a youth is otherwise eligible as a “child who is a candidate for foster care” and over age 18, the youth could be eligible for the title IV-E prevention program if:
    • a Title IV-E adoption assistance or guardianship assistance agreement is in effect with respect to the youth (that went into effect after the child attained 16 years of age)
    • the youth’s adoption or guardianship arrangement is at risk of a disruption or dissolution that would result in a foster care placement (section 475(13) of the Act)
    • the youth meets the State’s education/employment conditions as elected under title IV-E; and the youth has not yet reached the state’s highest elected age under title IV-E (19, 20 or 21).
  • If a youth is an otherwise eligible pregnant or parenting youth in foster care over age 18, the youth could be eligible for the title IV-E prevention program if:
    • the youth meets the State’s education/employment conditions as elected under Title IV-E; and
    • the youth has not yet reached the state’s highest elected age under title IV-E (19, 20 or 21).”

Yes. CDSS has created a web-based Comprehensive Prevention Planning toolkit to support the planning and implementation efforts of county child welfare and probation agencies, Tribes and their respective prevention partners which can be found on the recently launched FFPSA Overview Webpage. This toolkit includes the CPP Template which counties may choose to use to assist with the development of their CPP.

Wraparound is a strengths-based planning process put into place to address serious mental health or behavioral challenges involving children. High-Fidelity Wraparound refers to adherence to all four phases and all ten principles of Wraparound, and is defined as full alignment with the California Wraparound standards, as outlined in ACIN I-52-15.

Wraparound used by child welfare and probation agencies should always be delivered to a High-Fidelity standard to maximize the possible positive outcomes of a prevention and/or intervention plan. Wraparound is not yet Title IV-E reimbursable through the state’s Prevention Plan, however, inclusion of wraparound in the CPP will allow counties to use FFPS State Block Grant funds.

For more information, please see ACL 21-116 (September 30, 2021) and the California Wraparound Standards Toolkit. The FFPSA Part IV FAQs and FFPSA@dss.ca.gov email inbox are also available for inquiry.

The FFPS Program Early Opt In County Contact List includes the participating county child welfare and probation agencies and can be viewed on the CDSS FFPS Overview Website.

The allocation methodology and distribution are contingent upon how many counties opt-in. Allocations from counties who elect not to opt-in will be redistributed after an adjusted allocation methodology is completed. Further information will be provided to opt-in counties in a forthcoming CFL.

If the Letter of Intent (LOI) indicated that the probation department is not opting in, it is not required that probation sign the CPP or the assurances template.

Yes, this is correct. CDSS encourages the inclusion of both primary and secondary strategies in the local agencies’ comprehensive prevention planning activities and encourages counties to leverage cross-sector collaborative groups, county self-assessment processes, AB 2083 teams and any voluntary prevention planning efforts.

CDSS will issue additional guidance as needed. The candidacy determination is based on information gathered in a social worker or case manager’s professional assessment of each child and family’s unique circumstances and needs. The social worker or case manager’s assessment may result in learning information about the family that indicate that the child may be at imminent risk for foster care. The criteria for the child welfare or probation agency to determine candidacy should demonstrate that:

1. There are existing or ongoing risk factors impacting child or family well- being, and

2. Current circumstances of the family include factors of instability or safety threats that place them at imminent risk of foster care, and

3. The child(ren) can remain safely at home if prevention services (as designated in the state’s five-year Title IV-E prevention plan) are provided.

No. A separate plan is not required. The Assurances Template demonstrates that the local agency agrees to participate in State level fidelity monitoring, oversight, data collection, evaluation, and coordination to determine the effectiveness of a service provider under FFPSA. The expectation is for child welfare and/or probation Title IV-E agencies to sign the Assurances Template as a required component of the CPP and comply with forthcoming state guidance. The CDSS intends to contract with a single entity to provide assistance with monitoring and tracking model fidelity.

Yes. Family First Transition Act (FFTA) and FFPS SBG can be used to support participation of Tribes in the cross-sector collaboration process, such as participation in planning activities and ongoing CQI activities.

As outlined in CFL No. 20-21-91 (Page three), FFTA Grant funding can be used to engage in prevention and/or early intervention planning and planning activities will be captured using the FFTA administration and planning PROGRAM CODE (PC) 7981. As stated in ACL 21-47 (April 20, 2021) (Page four), it is required that counties use at least 50 percent of the Transition Grant funding to engage in prevention and/or early intervention planning, expand capacity for EBPs, and evaluation of activities directly related to the implementation of FFPSA Part I and/or allowable purposes under Title IV-B. Engaging and supporting Tribes’ participation in the development of the CPP falls within these activities and will count toward that 50 percent.

CFL No. 21-22-110 (Page eleven), provides PROGRAM CODE (PC) 1018 to capture costs associated with the FFPS SBG eligible administrative activities related to the development and implementation of comprehensive prevention services, including cross sector collaboration with Tribes for selection and development of services under the CPP. ACL NO. 22-23 (Page nine) states that engaging Tribes in cross sector collaboration is a required component of the CPP and that comprehensive prevention planning is an allowable SBG expenditure.

Counties should consult with CDSS to determine if a change or update is necessary, however, there is no limit to the number of times a CPP may be changed or updated. Per WIC §16588, counties shall promptly notify the department, in accordance with instructions issued by the department, of any changes to the comprehensive plan, including, but not limited to, an elimination or reduction of services. Counties are only required to submit changes to their CPP if the agency decides to make such changes. It is required, however, that cross-sector partners are re-engaged and CDSS notified of any revision to the CPP. Please see ACL NO. 22-23, for additional information.

Title IV-E prevention services may be provided to the following populations:

– Candidates for foster care, as described in section 475(13) of the federal Social Security Act and in the State Title IV-E Prevention Services Plan.

– Pregnant or parenting foster youth, including a child or nonminor dependent in foster care who is a parent, or expectant parent of an unborn child; and/or

– Their parents or kin caregivers.

For Title IV-E prevention services, section 475 of the federal Social Security Act defines “a child who is a candidate for foster care” as a child who is identified in a prevention plan as being at imminent risk of entering foster care but who can remain safely in the child’s home or home of a kinship caregiver as long as the necessary Title IV-E prevention services to prevent entry into care are provided.

California recognizes that while categories of children and families eligible for prevention services can be identified and referred to assess eligibility, “imminent risk” of foster care entry and candidacy can only be determined on a case-by-case basis, with thoughtful consideration for each child and family’s unique needs and circumstances, and with use of an unbiased process and/or tools to assess risk.

A local CPP is the plan developed by county child welfare and/or probation agencies which describes the services that the county will provide to address a continuum of primary, secondary, and tertiary prevention, intervention strategies and services.

The CPP must include Title IV-E prevention service(s) under the FFPS Program outlined in WIC§16585 through 16589. The CPP should also describe how the services will support the ability of parents and families to provide safe, stable, and nurturing environments for their children to help children remain at home and reduce foster care placements. ACL 22-23 provides a list of the components and requirements for the CPP, consistent with state and federal law. Counties are required to complete a needs assessment and asset mapping to determine the services to be included in their plan. Additionally, CDSS is providing child welfare and probation agencies with support during the development and implementation of their CPP, including a Comprehensive Prevention Planning Toolkit that will further support the development of the CPP.

Approved CPPs can be viewed at Approved Comprehensive Prevention Plans | (caltrin.org)

The California Department of Social Services (CDSS) recently launched an updated and revised FFPS Overview Website. The newly revised FFPS Overview Website provides important information and resources pertaining to the Family First Prevention Services Act (FFPSA), the Family First Prevention Services (FFPS) Program and the Comprehensive Prevention Plan Toolkit. This website also allows the CDSS to update resources and provide additional information quickly and efficiently and will serve as a hub for information regarding technical support.

Within the Title IV-E Prevention Services Clearinghouse, in the EBP section (Program or Service Delivery and Implementation Drop-Down menu), resources and information for each EBP can be located. If cultural adaptations are being made to an EBP, it is best to work directly with the purveyor, to discuss the specific cultural adaptations that are being considered to determine if the adaptation will impact model fidelity.

The Assurances Template can be located on the FFPSA Overview Website and is attached to ACL 23-23. The assurances are a required component of the local comprehensive prevention plan (CPP) and must be submitted by local child welfare services and probation agencies that opt into the FFPS Program.

Cross sector partners may vary by community, and at a minimum, must include representation from the other county agencies that serve families and children, Indian tribes, local community representatives, caseworkers, and individuals and families with lived experience with the child welfare system, in accordance with WIC §16585(b)(4) and WIC §16587.  Counties are strongly encouraged to include representatives from child abuse prevention councils.

Children who are not in foster care and residing in their homes or with a kin caregiver to prevent entry into foster care may qualify as a candidate for foster care and be eligible for Title IV-E prevention services. As defined in Social Security Act section 475, “a child who is a candidate for foster care” is defined as a child who is at imminent risk of entering foster care but who can remain safely in the child’s home or with a kinship caregiver with the necessary Title IV-E prevention services to prevent entry into care. This includes children whose adoption or guardianship arrangements are at risk of disruption that would result in a foster care placement.

Local child welfare and probation agencies and Tribes assigned to CDSS as their lead agency may use the CPP Support Request Form located on the FFPS Overview Website to request support for the planning and implementation of the FFPS program. After completing the CPP Support Request Form, CDSS will review the request and the CPP coordinator assigned to the agency or Tribe will be notified of the request.

Local child welfare and probation agencies or Tribes assigned to one of the other two lead agencies, Strategies TA or Casey Family Programs, should reach out to their representative for technical assistance and support. If the lead agency is unknown, Title IV-E agencies and Tribes may use the CPP Support Request Form to be directed to the appropriate lead agency.

The CDSS is currently working in collaboration with the Department of Healthcare Services (DHCS) on development of the payor of last resort and joint model protocol guidance.

The CDSS has recently implemented a technical support structure specifically designed to support the planning and implementation of local CPP’s. CDSS’ new technical support structure includes a “lead agency” cohort model and each opt-in county has been assigned to a cohort with either CDSS, Strategies TA, or Casey Family Programs as a lead agency for technical assistance and support. Lead agencies can provide subject matter expert resources and will serve as a first point of contact to assist with CPP development in partnership with CDSS. Technical support requests can be submitted by emailing FFPSAPreventionServices@dss.ca.gov or by submitting a request using the FFPS Program CPP Support Request Form which is located on the FFPS Overview Website.

The Capacity Assessment is a tool which agencies can use to determine motivation for change and readiness for embarking upon comprehensive prevention planning.  The tool is intended to facilitate conversations about buy- in and capacity of all partners to contribute to a comprehensive prevention plan in the community. Completing this tool online or submitting a hard copy to CDSS will help identify resources and technical assistance and support needed to build capacity and encourage cross-sector collaboration.  Counties can also request support with completing their capacity assessment by emailing FFPSAPreventionServices@dss.ca.gov.

Information about the State’s supports and resources can be found on the CDSS’  FFPS Overview Website and will be updated on an ongoing basis.

Yes.  ACL NO. 22-23 describes the necessary elements of the CPP, which includes the requirement that counties must describe how FFPS and State Block Grant funding will be used for prevention activities and services, as well as the extent to which additional funds will be leveraged for comprehensive prevention planning.

Counties are required to include in their CPP a local spending plan which describes how prevention activities and services in their CPP will be funded, including leveraging Title IV-E Prevention funds, FFPS State Block Grant funding, and other additional funds, as indicated in ACL No. 22-23.  The FFPS Prevention Funding Guide provides guidance to assist with funding planning and implementation of the Family First Prevention Services (FFPS) program, as well as the development of the Comprehensive Prevention Plan (CPP) components.

Yes.  A child whose guardianship arrangement is at risk of disruption or dissolution that would result in a foster care placement falls within the definition of a “child who is candidate for foster care” pursuant to 42U.S.C. § 675(13) of the Social Security Act and may access Title IV-E prevention services.  A child and their kin caregiver receiving Title IV-E prevention services are not considered to be in receipt of aid or assistance under the State plan for purposes of eligibility for any other program established under the Social Security Act, in accordance with 42 U.S.C. §671(e)(10). ?/ In addition, prevention services or programs cannot be construed to permit reduction of medical or other assistance available to the recipient.

Since the approval of California’s Title IV-E Prevention Plan on April 7, 2023, federal financial participation is available for specified administrative activities related to the implementation of Title IV-E prevention services.  It is anticipated these allowable administrative activities may be retroactively claimed from

October 1, 2021, if the county has manually tracked its activities for reimbursement.  However, this retroactive claiming will not include reimbursement for service costs for a child or family.  Further information can be found in CFL No. 21- 22-110.

Yes, community service providers are considered “other agencies/providers” and will use PC 1014 for training activities that are necessary for the proper and efficient administration of the State Title IV-E Prevention Program Plan. Please reference guidance provided in CFL No. 21-22-110 beginning on page six.

No. In California, a voluntary placement, as defined in WIC §11400(o)), is considered a foster care placement under 42 U.S.C. § 672(a)(2) and 45 C.F.R. Part 1355.20 of the Social Security Act.  Under federal program instructions set forth in ACYF-CB-PI-18-09, “a child may not be simultaneously in foster care and a ‘child who is a candidate for foster care,’ and therefore, a child who is placed out-of-home in a voluntary placement and their parent/kin caregiver will not be eligible to receive Title IV-E prevention services but may receive voluntary services funded by other sources.

Program guidance released in ACL NO. 22-23 provides information about both the FFPS SBG (Pages 10-12) and Title IV-E prevention (Page 13) funding available to support the planning and implementation of Title IV-E and comprehensive prevention services.  County specific allocations, allowable activities, and claiming instructions can be found on pages two and three of County Fiscal Letter CFL 21/22-84.  Time study definitions can be found on page three through twelve (Section-Title IV-E Prevention Activities) in CFL No. 21-22-110

It is not allowable to utilize Title IV-E funding to replace county funds, without maintaining the amount previously expended, as this may be considered supplanting.   Per the requirements set forth in WIC 16588, “A county shall use federal funds received under this chapter to supplement, and not supplant, local and State foster care prevention expenditures used for the maintenance of effort, as described in Section 471(e)(7) of the federal Social Security Act [42 U.S.C. Sec. 671(e)(7)].”  If the county continues to maintain previous levels of funding for a particular service, they can only use Title IV-E for funding services above and beyond what was previously provided.

However, if the county decides to expand on its current program (e.g., expanding the services provided and/or increasing the population being served), the county may draw down the Title IV-E funds to supplement the difference.

For example, if the county is already administering a Title IV-E eligible EBP, such as Child-Centered Group Play Therapy, using local funding but wants to institute a culturally responsive adaptation of the practice, Title IV-E funding could supplement the existing funding.

If a county implements a new program, it may use Title IV-E and State Block Grant to help implement the program.  Please refer to County Fiscal Letter CFL No. 21-22-110 for SBG claiming instructions and allowable funding expenditures. 

The CWD and probation have their own separate allocation. If the probation department chooses to not opt in, the probation allocation would be redistributed to counties that have opted in to the FFPS program.

SBG funding under the FFPS program can be used for primary, secondary, and tertiary prevention activities.  In order to claim federal financial participation under Title IV-E, the services must be included in the State’s Prevention Plan, and meet all required criteria listed on page two of CFL 21/22-84.

The CDSS recognizes that additional well supported EBP’s have been added to the Title IV-E Prevention Services Clearinghouse since the submission of California’s state plan to the ACF.  Additional EBP’s may be added in the future to the state’s Prevention Plan in accordance with the annual review process described in WIC §16588.

No. Federal and State funds cannot be used to purchase automation systems for the FFPS program. However, county-level funds can be used for this purpose if an Advance Planning Document (APD) is submitted. An APD can be processed through the State Office of Systems Integration (OSI), as outlined in CFL 20-21-59 (January 12, 2021).

Development of limited functionality of FFPSA Part I to enable Title IV-E claiming was considered for early release in CWS-CARES version 1.  In July 2022, the Board of Directions voted that such an early release was not feasible.  As such, functionality for FFPSA Part I will still be included in CWS- CARES version.  CARES Version 1 (V1) will replace and retire CWS/CMS and will go-live in October of 2026. 

Until CARES automation, Title IV-E agencies  will not be able to draw federal Title IV-E prevention funds for individual client specific expenses.  Administrative costs, however, will be reportable and can be claimed as federal Title IV-E expenditures using the claiming codes outlined in CFL No. 21-22-110.