Crittenton 2015 Policy Platform

Purpose of Platform:Crittenton Services for Children & Families is a 501(c)(3) child-welfare agency headquartered in Fullerton, California. With offices spread over five counties (Los Angeles, Orange, Riverside, San Bernardino and San Diego), Crittenton is proud to serve a diverse and broad base of clients and their communities. Since the late 1800’s the Crittenton legacy is firmly based in the belief that all children deserve a happy, healthy home in which to grow, and we continue that work throughout Southern California today.

Crittenton’s services range from intensive, therapeutic residential care for significantly broken youth, to community based programming including foster care, Wrap Around services, THP+ and prevention resources. Specialty programming for children who have been victims of sex trafficking, are pregnant and parenting, struggle with substance abuse issues or have co-occurring mental health problems allow Crittenton to work with the most troubled children in the region who are often referred to as “hard to place.” The compassion and expertise of Crittenton staff is reflected in the breadth of services and treatment modalities offered, and based in a restorative-justice model grounded in mental health.

In furtherance of our mission, “….to help heal the wounds of abuse and neglect; to strengthen families, whether birth, foster or adoptive; and to help troubled adolescents reach their full potential,” Crittenton staff identified the following 6 policy priorities to guide the agency’s legislative and advocacy efforts in 2015.

Questions or comments regarding this document should be directed to Stefanie Benvenuto, Director of Public Policy & Advocacy at , or (562) 427-2006.

  1. Protecting and preserving the proven services and treatment options available to Crittenton clients currently while expanding system delivery via formal partnerships and new, innovative alliances at various levels of government.

Major reforms being floated by advocates at various levels of government indicate that the child welfare and juvenile justice system are potentially on the verge of significant changes that will directly impact the most vulnerable of Crittenton’s client population. It is important to the agency that any new legislation:

(1.1)Acknowledges and endorses the fact that no one treatment will work for all individuals.

(1.2)Promotes a variety of treatment options and tools to most effectively address the unique needs of any parent, child or family that is in need.

(1.3)Protects existing treatment options and placements without arbitrary regulations that are not based in best practices or research.

(1.4)Very clearly place the needs of vulnerable and at-risk families and children above all else, understanding that they (at best) face major barriers in self-advocacy.

(1.5)Approach reform with an intentional emphasis on transparency and communication with stakeholder groups.

Policy Recommendation #1: Legislation requiring additional research into the unintended consequences of normalcy standards that may inadvertently place children with higher levels of need at risk due to unrealistic expectations while in care.

  1. Combatting the trafficking of minors through prevention, intervention and reintegration programming paired with a robust effort to deter demand.

Crittenton remains one of a handful of agencies in Southern California with an established expertise in serving minor victims of trafficking, both international and domestic, labor and sex. Our experience has informed our legislative advocacy for this population of victims and, most recently, has resulted in a robust effort to defend these children from well-meaning policy that would have unintended consequences potentially resulting in more harm than good. Consequently, Crittenton supports legislation that:

(2.1) Holds predators (both purchasers and exploiters) accountable.

(2.2) Utilizes psychological/clinical treatment interventions that effectively address the severe early childhood complex traumas that many trafficking victims suffer from.

(2.3) Authorizes a continuum of care response for victims, acknowledging that a “one size fits all” approach to this issue will inevitably result in some children being left without adequate or appropriate care as they heal.

(2.4) Empowers the community as a whole by arming them with resources and tools to better advocate for the needs of children they believe are most at risk.

(2.5) Acknowledges the challenges to serving trafficking victims from a regulatory and licensing perspective by finding new, safe and effective ways of providing oversight to direct-care providers of this population.

Policy Recommendation #2: Amend the California Penal Code 647(b) pertaining to prostitution to make it a 266(e) charge when a minor is being procured for the purpose of prostitution or other commercial sex exchange. Additionally, require any adult who solicits, attempts to engage, or engages with a minor in an act of commercial sex to register as a sex offender, under penal code 290.

  1. Implementation of the Continuum of Care Reform.

The Continuum of Care Reform (CCR) proposal is the result of a collaborative effort between the California Department of Social Services, the state’s Child Welfare Directors Association and the California Alliance of Child and Family Services. The general framework for the sweeping reform has been agreed upon by stakeholders, and implementation is expected to kick off in 2015. However, as legislation codifies these changes, we are particularly interested in the enactment of the following portions of the reform:

(3.1) Ensures that all children in need are able to access timely, appropriate and professional services that are determined not by bureaucratic policy but instead by the child’s circumstances.

(3.2) Updating the assessment process to provide statewide uniformity in identifying the correct and appropriate placements.

(3.3) Strengthening the training and qualification requirements for families caring for foster youth as well as staff at Short Term Residential Treatment Centers.

(3.4) Improving the mental health service delivery to all children in care by requiring STRTC’s and foster family agencies to be certified by counties through their county mental health plan.

(3.5) Maintains current momentum and protects the CCR proposal from minimizing amendments or delay.

Policy Recommendation #3:Passage and enactment of AB 403 (Stone) to codify the aforementioned portions of CCR.

  1. Prioritizing the unique mental health needs of children by identifying and implementing the most appropriate service delivery models.

The overwhelming majority of clients served by Crittenton, whether in the home or at our residential facility, struggle with significant mental health issues. These issues are often compounded by additional stressors such as substance abuse, poverty or residing in communities in crisis. It is the belief of Crittenton that the mental health needs of children are vastly different from those of an adult and therefore must be treated with an understanding of a child’s development, family structure and overall needs to ensure that they grow up and thrive. While it is generally agreed upon that a child struggling with mental health deserves appropriate treatment, challenges are ahead for professionals in the field due to the implementation and unforeseen consequences of policies such as the Affordable Care Act (ACA). Crittenton then, advocates for legislation that would:

(4.1)Recognize the unique mental health and substance abuse needs of children in care.

(4.2)Encourage a network of specialized, professional services that can effectively work in the community with traditionally-difficult or hard-to-treat populations.

(4.3)Maintain a focus on resiliency when treating children with mental health needs and avoid, an irresponsible overreliance on psychotropic medications.

(4.4) Recruit and retain qualified mental health professionals with a passion for working with troubled and at-risk youth.

(4.5) Consider the long-term structure that will deliver mental health services for system-involved youth in the context of ACA implementation and CCR.

Policy Recommendation #4.2: Authorize legislation for specific pilot programs in local counties to investigate alternative partnerships between specialty mental health providers and larger healthcare managed plans to provide intensive community based services.

  1. Ensuring that pregnant and parenting foster youth youth are empowered to parent their children and end the cycle of system-involvement.

Crittenton’s legacy is built upon a history of working with pregnant and parenting victims of trafficking in the 1800’s. Our work has continued to focus heavily on this population, and while we celebrate the progress made on behalf of teen parents, we are concerned that said progress has not extended to teen parents who are simultaneously system-involved. The pregnant and parenting subset of foster youth are a unique group of young, fragile parents who may benefit most from intervention services that reinforce positive parenting themes and bonding with children, as it can result in ending the cycle of system-involvement. Our expertise with this population leads us to support legislation that:

(5.1) Engages and empowers pregnant and parenting foster youth in their case plans, management and parenting decisions (to the extent possible and appropriate).

(5.2) Ensures sufficient training, education and preparation for caregivers and other authority figures in the lives of these dependents and their children.

(5.3) Provides specialized services whether in community-based or out of home care for this population that better meets their needs.

(5.4) Reforms the current structure to provide services to pregnant and parenting dependents that will adequately prepare them for their future following their exiting the system.

Policy Recommendation #5:Clarify federal Title IX, directing states to require school districts and local education agencies develop and implement policies to effectively support teen parents with an emphasize on teen parents who may also be system involved.

  1. Improving outcomes by increased integration of trauma-informed services, models and systems.

Across the various programs Crittenton provides to clients is the common thread of trauma, or adverse childhood experiences (ACES). More recent work being done at the national level by Crittenton and its affiliates have honed in on the more relevant traumas to children growing up in poverty stricken and violent communities, who we know are already have a greater likelihood of system involvement than their peers. Crittenton advocates for legislation that better focuses on traumatized youth, that:

(6.1) Mandates all children entering, or identified to be at-risk of entering, the child welfare or juvenile justice systems be screened for trauma.

(6.2) When possible, provide trauma informed services not only to caregivers and youth, but to bio-families to better educate parents and prevent future trauma.

Policy Recommendation #6: Reintroduce H.R. 4016 (DeLauro), the Quality Foster Care Services Act of 2014, that requires therapeutic foster care (TFC) programs to be state licensed, providing uniformity to the service delivery across the country. In addition, would dictate trauma-informed and gender-responsive services for high-need youth in these specified foster homes that are well-versed in the effects of significant and complex trauma.