Sil Orlando and Elias Lefferman
January 13, 2009
Page 1 of 6
/County of Los Angeles
DEPARTMENT OF CHILDREN AND FAMILY SERVICES425 Shatto Place, Los Angeles, California 90020
(213) 351-5602PATRICIA S. PLOEHN, LCSW
Director
January 30, 2009 Draft
Sil Orlando, President
ACHSA Board of Directors
1200 Wilshire Blvd., Suite 302
Los Angeles, CA 90017
Elias Lefferman, Chair
ACHSA Family Based Services Subcommittee
1200 Wilshire Blvd., Suite 302
Los Angeles, CA 90017
Dear Sil and Elias:
I would first like to thank you again for the ongoing discussions about Wraparound and the upcoming Wraparound contract. It is clear we are all very invested in making the appropriate adjustments to Wraparound that will continue to produce wonderful outcomes.
After receiving your letter on December 17, 2008, theWraparound administration and DCFS leadership met to discuss your concerns and I wanted to update you about our position on the issues highlighted in your letter. We reviewed each issue thoroughly and believe that although we do not agree with changing every issue, we did make changes and believe they are fair and equitable. Our itemized responses to your issues are listed below. Again, we appreciate your ongoing partnership and hope to continue our collaboration and ongoing conversations to continue to make Wraparound a wonderful program for our families.
Outstanding Issue #1: Definition of Parent Partner -"Parent Partner shall be defined as an employee of a Lead Wraparound Agency who is or has been the parent or primary caregiver (not a foster parent)of a child who was/is involved in one of the referring Departments (Department ofMental Health, Probation Department, Department of Children and Family Services) or Regional Center. A parent partner must, at the time of hire, no longer have an open case with either Probation or DCFS."
ACHSA proposed language: "Parent Partner shall be defined as an employee of a Lead Wraparound Agency who is or has been the parent or primary caregiver of a child who was/is involved in one of the referring Departments (Department of Mental Health, Probation Department, Department of Children and Family Services) or RegionalCenter. A parent partner must, at the time of hire, no longer have an open case with either Probation or DCFS."
DCFS response: Although the cited foster parent with twenty-five years of experience would be a wonderful addition to the Wraparound team, they do not fit our definition of a parent partner. As I said in our meetings, Wraparound is about relationships and trust and having a parent/primary caregiver sit across from another parent/primary caregiver, who is able to say, “I’ve been there and we will get through this” is one of the most powerful moments many of our families will ever experience. A foster parent, despite their many years of experience, or number of children in their care, cannot say with the same conviction, “I’ve been there and we will get through this.” We feel very strongly on this point and know there are a good number of your providers who agree with our position.
In addition, we want to work with you on the issue of available pool ofprospective Parent Partners. We understand there are challenges, but are committed to helping address this issue.
Outstanding Issue #2: Definition of Tier I -"Tier I shall be defined as Wraparound for children and youth residing in, or at imminent risk of entering residential care RCL 10 and above and who are within 60 days ofretuning to the community. Tier I shall be paid at the rate of $4,184 per month, per child/youth, less any placement costs."
ACHSA Proposed Language: "Tier 1shall be defined as Wraparound for children and youth residing in, or at imminent risk of entering residential care RCL 10 and above and who are within 60 days of returning to the community. Tier I shall be paid at the rate of $4,184 per month, per child/youth,plus EPSDT, less any placement costs. This rate will be revisited after a one year period of studying actual provider costs, based upon a methodology to be developed jointly by DCFS and the Wraparound agencies."
DCFS response: We cannot include EPSDT for Tier I because DCFS is not able to commit EPSDT funds for every Tier I Wraparound child. As you know, there are some Wraparound enrollees who do not have EPSDT and including EPSDT would imply every enrollee should receive EPSDT.
DCFS is committed to providing fair and equitable contracts, so we will commit to another “actual cost data report”to be completed by the beginning of 2010. We will develop a joint provider/County workgroup to discuss the methodology on how the information is collected and reported.
Outstanding Issue #3: Definition of Tier II -"Tier II shall be defined as Wraparound for DCFS children/youth who have an open DCFS case, qualify for Early and Periodic Screening Diagnostic and Treatment (EPSDT) and have an urgent and/or intensive mental health need which causes impairment at school, home and/or in the community. Tier II shall be paid at the case rate of$1,300 per month, per child/youth, without any placement costs deducted."
ACHSA Proposed Language: "Tier II shall be defined as Wraparound for DCFS children who do not meet enrollment criteria for Tier I and who are EPSDT eligible (see definition for EPSDT). Tier II shall be paid at the case rate of $1,250 per month, per child/youth, plus EPSDT, without any placement costs deducted."
DCFS response: Agreed. EPSDT (as appropriate) will be added because EPSDT was identified as an eligibility requirement. (Please note that all financial language is contained in the contract and not the SOW)
Outstanding Issue #4: Transfer -"Transfer shall be defined as when a child/youth and/or their family moves from one SPA to another SPA and the Wraparound provider is not contracted for the new SPA, and/or the new location is farther than 30 miles outside ofthe contracted SPA. The provider will work with the ISC to complete a transfer to another Wraparound provider. The sending provider will continue to provide full Wraparounduntil the receiving provider enrolls the child/youth and/or their family."
ACHSA Proposed Language: "Transfer shall be defined as when: 1) a child/youth and/or theirfamily moves from one SPA to another SPA; and 2) the Wraparound provider is not contractedfor the new SPA and the new location is farther than 30 miles outside ofthe contracted SPA; and 3) itreflectsthebestinterestofthechild, asdetermined by the CFT. The provider will work with the ISC to complete a transfer to another Wraparound provider. The sending provider will continue to provide full Wraparound until the receiving provider enrolls the child/youth and/or their family."
DCFS response: We certainly appreciate ACHSA’s point and have incorporated the “30 mile” clause to try to address the continuity concern, but if the provider is not contracted in the new SPA and the family is farther than 30 miles outside of the original contracted SPA, we believe they must transfer. This goes back to earlier conversations about availability to families in emergencies and our concern about meeting the family’s needs. Although providers can not provide Wraparound in a SPA that they are not contracted to serve, they will have an opportunity to bid for an additional SPA, when a need is identified by the County and the community.
Outstanding Issue #5: Facilitator -"Contractor shall assign a SPA specific Facilitator to every Tier I Wraparound child at a maximum ratio ofone (I) Facilitator for every ten (10) active Wraparound children (1:10). Contractor shall assign a SPA specific Facilitator to every Tier II Wraparound child at a maximum ratio of one (1) Facilitator for every fifteen (15) active Wraparound children (1:15). Facilitators shall be specifically assigned to Wraparound full-time, and Contractor shall not assign Facilitators any cases from any other programs as long as they are employed as Wraparound Facilitators."
ACHSA Proposed Language: "Contractor shall assign a Facilitator to every Tier I Wraparound child at a maximum ratio of one (I)full-time equivalentFacilitator for every ten (10) active Wraparound children (1:10). Contractor shall assign a Facilitator to every Tier II Wraparound child at a maximum ratio ofone (l) full-time equivalent Facilitator for every fifteen (15) active Wraparound children (1:15). Facilitators shall be specifically assigned to \\'raparound full-time, and Contractor shall not assign Facilitators any cases from any other programs as long as they are employed as Wraparound Facilitators."
DCFS response: As discussed in our previous meetings, having facilitators understand the community and be locally available to families is crucial. However, we understand the logistical, geographical and fiscal issues this requirement causes and are going to eliminate the SPA specific language for both the facilitator and parent partner. We will add language that was suggested in one of our meetings that facilitators and parent partners may only serve geographically adjacent SPAs. We want to monitor this closely with you and revisit if we find that that outcomes and staff turnover are being impacted.
On the issue of full time equivalent, the current contract requires staff to be dedicated to Wraparound and available 24/7. We believe that if the employee was “hired” in another program, their availability would be compromised. We also believe with the new expansion (tier II) we will need all Wraparound staff to be dedicated to Wraparound. The expansion (tier II) begins in May and with the identified need and large number of referrals planned, we believe we will need every available resource. We also believe for the positions of the facilitator and the parent partner, these are especially crucial.
Outstanding Issue #6: Parent Partner -"Contractor shall assign a SPA specific Parent Partner to every Tier I Wraparound child at a maximum ratio of one (l) Parent Partner for every ten (10) active Wraparound families (10). Contractor shall assign a SPA specific Parent Partner to every Tier II Wraparound family at a maximum ratio of one (l) Parent Partner for every fifteen (15) active Wraparound families (I:15). Parent Partners shall be specifically assigned to Wraparound full-time, and Contractor shall not assign Parent Partners any cases from any other programs as long as they are employed as Wraparound Parent Partners. The Parent Partner is to work closely with the Wraparound child's parent/caregiver in order to represent their best interests and shall participate as a member of the CFT.
If a parent/caregiver declines assignment of a Parent Partner, the parent/caregiver shall write "Assignment of Parent Partner declined at this time" on the signature page of the POC, and sign and date the POC on the Parent Partner signature line. Contractor shall periodically readdress/reassess the parent's/caregiver's need/desire for assignment ofa Parent Partner. If the caregiver declines assignment of a Parent Partner, that caregiver's family shall not be counted as part of the Parent Partner maximum ratio."
ACHSA Proposed Language: "Contractor shall assign a SPA specific Parent Partner to every Tier I Wraparound child at a maximum ratio of one (1) full-time equivalent Parent Partner for every ten (10) active Wraparound families (1:10). Contractor shall assign a SPA specific ParentPartner to every Tier II Wraparound family at a maximum ratio of one (1) full-time equivalentParent Partner for every fifteen (15) active Wraparound families (1:15). Parent Partners shall be specifically assigned to Wraparound full time, and Contractor shall not assign Parent Partners any cases from any other programs as long as they are employed as Wraparound Parent Partners. The Parent Partner is to work closely with the Wraparound child's parent/caregiver in order to represent their best interests and shall participate as a member ofthe CFT. Ifa parent/caregiver declines assignment of a Parent Partner, the parent/caregiver shall write "Assignment ofParent Partner declined at this time" on the signature page ofthe POC, and sign and date the POC on the Parent Partner signature line. Contractor shall periodically readdress/reassess the parent's/caregiver's need/desire for assignment of a Parent Partner. Ifthe caregiver declines assignment of a Parent Partner, that caregiver's family shall not be counted as part ofthe Parent Partner maximum ratio."
DCFS response: As discussed in our previous meetings, having facilitators understand the community and be locally available to families is crucial. However, we understand the logistical, geographical and fiscal issues this requirement causes and are going to eliminate the SPA specific language for both the facilitator and parent partner. We will add language that was suggested in one of our meetings that facilitators and parent partners may only serve geographically adjacent SPAs. We want to monitor this closely with you and revisit if we find that that outcomes and staff turnover are being impacted.
On the issue of full time equivalent, we believe that if the employee was “hired” in Wraparound they need to be trained and dedicated to that program. Additionally, if the employee is hired for another program, their availability would be compromised. We also believe with the new expansion (tier II) we will need all Wraparound staff to be dedicated to Wraparound. The expansion (tier II) begins in May and with the identified need and large number of referrals planned, we believe we will need every available resource.
Outstanding Issue #7: CANS -"Child and Adolescent Needs and Strengths (CANS), Exhibit A-8. Contractor shall conduct the CANS every six (6) months to assess changes in functioning which will inform level of care decisions."
ACHSA Proposed Language: "Child and Adolescent Needs and Strengths (CANS), Exhibit A-8. Contractor shall conduct the CANS every year to assess changes in functioning which will inform level of care decisions."
DCFS response: In consultation with Dr. John Lyons, six months is the appropriate span for the administration of the CANS. The CANS will assist both the Department and the providers in making informed decisions regarding specific areas of strengths and concerns and used in conjunction with the POC review (6 months review), we believe it will create a comprehensive review process to ensure safety and expedite permanency (At the six months POC review, an accompanying CANS will be presented to help the ISC team understand the strengths and needs of the family and compare them with the presented POC). Additionally, the six month POC review with the CANS will align and assist with the case worker’s responsibility to provide court with the most detailed and comprehensive information for the six month status review. The Court’s six month review cycle is intended toassist in the timely reunification and permanency and waiting for one year to conduct a CANS would not allow the court to benefit from the additional information and may delay a child/youth’s return or services that they need.
DCFS also appreciates the continued efforts of ACHSA to provide input to the upcoming Wraparound SOW. We value your partnership and commitment to make Wraparound an outstanding program for families in Los AngelesCounty. Please note that above changes will not take effect until May 2009.
Again, we value your work and acknowledge your wonderful efforts to make Wraparound what it is today. We hope the new changes will only strengthen Wraparound for the years to come.
Sincerely,
Michael J. Rauso, Division Chief
Multi-Agency Services Division
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