Note: This post was originally published in 2017. Now that it’s 2020, we decided to give it an update. The core information remains the same.
Social service agencies across the world have voluntarily risen to the challenge of achieving accreditation. Whether their original goal was to focus on administrative functions or service delivery quality, the accreditation process (particularly with a whole-organization accreditation approach) provides these agencies with a blueprint to refine practices simultaneously across every area of the organization. The performance of these agencies has caught the eye of oversight entities and consumers alike, prompting accreditation to be used has a regulatory tool through mandates.
The word ‘mandate’, particularly in a government context, is notorious for creating concern across service providing agencies, often because of the cost associated with those requirements. COA believes all mandates function best when paired with the funding required to meet those mandates. We encourage all regulatory entities to consider the financial impact of any imposed mandate, as it can make or break the success of these initiatives.
Though the financial concerns of these agencies are absolutely valid, we can’t ignore the positives that can come with an accreditation requirement. Through accreditation, agencies are given a path to meet a base-level of quality across administrative and service delivery functions. Accreditation sets clear service expectations for service recipients and the taxpayers that fund these programs alike. It also fosters a culture of continuous improvement that can ensure the sustainability of an agency’s services. We cannot ignore the importance of these tenets in growing and maintaining a strong social service system that meets the needs of our communities.
To hopefully make this all a little easier on your organization, we’ve creating this guide to support your agency in navigating a mandate. Our goal is to help you gather important details, understand what is required, determine milestones, and know how to compare and contrast accreditors.
Note: Our best advice is don’t delay! Expect that it will take up to six months to determine an accreditor and then 12-18 months to pursue and achieve accreditation.
Questions for the entity that mandated your accreditation
What accrediting bodies are accepted?
Usually a mandate will include a list of accepted accreditors. If this isn’t included, reach out to the payer to find out what accreditors are accepted. If your preferred accrediting body isn’t recognized, we encourage you to reach out to that accrediting body and let them know. We can only speak for COA, but we are always willing to work with you and regulating entities to have COA accreditation be accepted under a mandate.
What service(s) is/are mandated?
Does the mandate apply to one service? Many services? The entire organization? Is there a document that crosswalks which services are mandated and what standards need to be applied by the accreditors? COA Accreditation Coordinators often know which service standard assignments are required for a mandate, but we always think it’s best for you yourself reach out to your regulatory entity to determine what is exactly required for your agency and the services you are providing.
What is due and when?
Mandates often come with specific timelines and may even have multiple milestone requirements. In these instances, regulating entities will designate a deadline for achievement of accreditation. To ensure organizations are on track to meet a deadline, regulating entities will designate milestone deadlines on the way to an accreditation award – a date by which organizations must engage with an accreditor, a date by which organizations must have their Site Visit, and then a date by which an award must be received.
What type of accreditation award is needed?
It’s important to clarify what type of accreditation award is due and when. Some accreditors offer provisional or temporary accreditation. Accreditors and regulatory entities will work with your organization to determine the type of accreditation award that is required under your mandate.
Evaluating accreditors — features to consider
Once you know which of your programs needs to be accredited, by when, and by whom, reach out to all the approved accreditors and get an understanding the features of each. Regulatory entities and some membership groups will often facilitate panels with all recognized accreditors to help providers select the accreditor that is best for their agency. Here are some questions you’ll want to ask:
How much does your accreditation process cost?
Ask about application fees, accreditation fees, Site Visit fees (scheduled and unscheduled), and maintenance fees. Is there a fee to purchase the standards? If so, how many copies will you need and how often will updates be published in the future? Make sure to ask about required fees and optional fees. For example, trainings might be required and have associated fees.
What is awarded and how long is it valid?
Each accrediting body will have a different length of accreditation award. This is referred to as an ‘accreditation cycle’, which will let you know how long your award is valid and how often you can expect to go through the accreditation process. Some mandates require a specific award length, in these cases the approved accreditors have worked with your oversight entity to meet this regulatory requirement. It’s important to keep all of this in mind when evaluating cost – how many accreditation cycles will your organization undergo over time (including provisional cycles)?
What is included in the accreditation review?
Will the accreditor require all programs to pursue accreditation, or can you isolate individual programs? Will the administration and management areas of the organization be reviewed? Will every site be visited in the review (important to keep in mind when considering cost!)? Does the approach of the accreditor fit your organizational culture? Does the accreditation cover all of the desired service areas (current and future growth plans)?
We encourage all agencies to look toward future mandates as well. We have often seen additional services mandated, and agencies that utilized an accreditor with a whole-organization approach are most prepared for any mandate that comes their way.
How long does it take?
Most accreditation processes take 12-18 months from deciding to pursue to decision. However, the right time to sign up might vary with each accreditor. For example, some accreditors want to hear from you when you’re ready for your Site Visit within 4-6 months. Other accreditors want you to apply before your self-assessment period so that they can work alongside your organization in preparation for the Site Visit.
How is my organization supported throughout the process?
Are you assigned a point person to work with from the accrediting body? Does the accreditor offer trainings? How and when can you ask questions? Does the accreditor provide templates and other tools to support you? Is there an online management system to assist with managing the process? Though every accreditor provides different tools to support agencies in meeting their mandate, it’s important to assess how much guidance and assistance will help your agency thrive in this process.
What is required to maintain our accreditation status?
Once accredited, what is your responsibility for self-reporting changes at your organization? What is the process when your organization adds a new program or a new site? Are there annual reporting requirements and fees? What is your responsibility when it comes to implementation when standards change?
Ask peer organizations
Contact a few peer agencies that are already accredited. Think about the characteristics you should consider when identifying a peer – is it population they serve? Their size? Location? Mission? Ask your peers about their satisfaction with the accreditation process, how they managed the work, and when appropriate, if they’d be willing to be a resource while you pursue accreditation.
Ask internally – staff, board members, and volunteers
Start a discussion about their accreditation experiences and what they liked or disliked about the process. This is also an opportunity to gauge interest to see who would be willing to be part of the accreditation team or even lead the accreditation effort within your organization.
Ask your membership associations
If you belong to an association, ask if they support accreditation. Some associations have relationships with accreditors which might make your organization eligible for a discount when pursuing the process. Some offer technical assistance, and many are willing to facilitate dialogue around accreditation.
Hopefully, this information will assist your organization with mapping out your journey towards seeking accreditation.
Here are some related resources we have available.
- Tips for Creating Effective Workgroups
- What’s the difference between accreditation, licensing and certification?
- Accreditor Comparison
Please feel free to share other resources you’ve found helpful while navigating this topic in the comments below!
Since Congress passed the Family First Prevention Services Act (FFPSA) in February 2018, stakeholders across the U.S. have been working to maximize the opportunity posed by this tremendous reform to our child welfare system. To ensure that children and families reap the positive benefits of FFPSA, service-providing agencies, social workers, child welfare officials, accrediting bodies, policy makers, and advocacy organizations have been rigorously planning for implementation, all while trying to keep up-to-date on the latest guidance and policy.
Looking for an FFPSA 101? Watch our informational video.
As COA began working with service providers impacted by FFPSA, we found that organizations were not only interested in information about the accreditation process, but also resources relevant to the larger scope of FFPSA provisions. That’s why we created the COA FFPSA Resource Center, a hub of FFPSA-related content including federal guidance, tools and resources, accreditation information, events and trainings, and news.
We are continually evolving the website as new guidance and/or policy is released and as states move forward with implementation. Have a resource, article, or tool that you’d like to see posted on the Resource Center? We’d love to hear from you! Reach out to us by email at PublicPolicy@coanet.org.
Just starting to peruse the site and not sure where to start? Fear not! We’ve created a list of 5 helpful resources to get you started.
1. Federal Requirement Comparison: QRTP and PRTF
From the Building Bridges Initiative
With the support of the Annie E. Casey Foundation, Building Bridges created this comparison to assist providers in understanding the federal requirements set forth for Qualified Residential Treatment Programs (QRTP) and Psychiatric Residential Treatment Facilities (PRTF). The information is organized in a table by requirement component, so that readers can do a line-by-line comparison of each program’s respective requirements. Though QRTPs and PRTFs have some similarities, these programs were created and defined separately in federal law in order to establish varying levels of care for children and youth with significant behavioral health needs.
Building Bridges is a national initiative working to identify and promote practices and policies that will create strong coordinated partnerships and collaborations between families, youth, community- and residentially-based treatment and service providers, advocates, and policy makers to ensure that comprehensive mental health services and supports are available to improve the lives of young people and their families.
View the comparison here.
2. Responsibly Defining Candidacy within the Context of FFPSA: 5 Principles to Consider
From the Center for the Study of Social Policy
The Center for the Study of Social Policy created this brief of guiding principles for states to consider as they work to identify a definition of foster care candidacy that fits within the context of their state policies and prevention service array.
FFPSA defines the term ‘child who is a candidate of foster care’ to mean “a child who is identified in a prevention plan under section 471(e)(4)(A) as being at imminent risk of entering foster care…but who can remain safely in the child’s home or in kinship placement as long as services of programs specified in section 471(e)(1) that are necessary to prevent the entry of the child into foster care are provided” (Sec. 50711). This means each state will be responsible for defining candidacy in their State IV-E Plan, which will be submitted to the Children’s Bureau. State definitions of “candidacy” will be extremely important in deciding which children and families will be served under FFPSA prevention services. This resource provides a guiding methodology for state policymakers in creating that definition and assists in considering the way such a policy will impact children and families in their state.
View the resource here.
3. Program Standards for Treatment Family Care
From the Family Focused Treatment Association (FFTA)
As we learn more about the impact that FFPSA implementation will have, it has become clear that there is a need to bolster the continuum of child welfare services offered to meet the needs of children and families. Treatment Family Care (TFC), also known as Treatment Foster Care (TFC), has emerged as a leading service to meet the behavioral needs of children in home-settings rather than residential care. The strict parameters established around residential placement under FFPSA puts a spotlight on TFC as a service that can maintain a residential level of care while keeping children and youth in a home-setting.
Though TFC services are provided across the country, federal guidance related to funding opportunities, practice standards, and program oversight has never been issued. Fortunately, Congress is currently considering the Treatment Family Care Services Act (HR3649 and S1880), which will provide states with a clear definition and guidance on federal TFC standards under the Medicaid program and other federal funding streams. This clarification will promote accountability for states offering TFC, support FFPSA implementation, promote appropriate TFC services for reimbursement, and drive personnel training and standards.
FFTA first published their own Program Standards for TFC in 1991 to define the model and set parameters for the field. In 2019, FFTA published the revised 5th edition, which provides several updates to the previous edition and in particular approaches the standards from a broader perspective of Treatment Family Care. This is in response to the changing needs of children, youth, and families; programmatic changes; and service expansions impacting TFC services. In particular, the new edition expands the view of TFC by integrating a focus on children living with kin. This inclusion was necessitated by an increasing expectation to meet the treatment needs of children in kin settings, stemmed by the belief that living with family can minimize the trauma associated with separation from parents.
View the FFTA’s program standards here.
4. Title IV-E Prevention Services Clearinghouse website
From the U.S. Administration for Children and Families (ACF)
The Title IV- E Prevention Services Clearinghouse was established in accordance with FFPSA by the Administration for Children and Families (ACF) within the U.S. Department of Health and Human Services (HHS). Its goal is to conduct an objective, rigorous, and transparent review of research on programs and services intended to support children and families and prevent foster care placements. Programs submitted to the Clearinghouse are rated as “well-supported”, “supported”, “promising practice”, or as “not meeting criteria”. The initial programs that have been rated include mental health services, substance abuse prevention and treatment services, in-home parent skill-based programs, and kinship navigator programs.
Ratings will help determine programs’ eligibility for reimbursement through Title IV-E funding. The Clearinghouse continues to be updated as new services are reviewed and rated, those interested in receiving real time notifications of updates can sign up here.
Access the Title IV-E Prevention Services Clearinghouse here.
5. National and state FFPSA news
From our FFPSA Resource Center
Implementation of FFPSA will mark the largest reform to our national child welfare system in decades. Since FFPSA passed in February 2018, there have been hundreds of news outlets reporting on the many components of reform at the national and state level, including information on implementation, related legislation, funding opportunities, service delivery, and more. The large scope of provisions can make it difficult to find the information that is relevant to your role in implementing FFPSA. That’s why COA created a FFPSA news round-up, updated regularly with content published related to state-specific activities and national news related to FFPSA.
State-level news can be viewed here and national-level news can be found here. Want to get alerts when important updates are published? Sign up for our mailing list.
We hope these resources will support you and your agency in learning more about the provisions of FFPSA. We would like to thank all of the organizations that have produced content to assist our field with this important legislation.
Though we’ve identified these five resources to get you started, we encourage you to continue your research and explore all of the information available at www.coafamilyfirst.org. And since we couldn’t pick just five…
Accreditor Comparison Guide
Needing to pursue national accreditation as a result of FFPSA? The first step is to find an accreditor that is the right fit for your organization. To support agencies in choosing an accreditor, we created a comparison guide that details the differences between the COA, CARF, and JC accreditation processes.
Download the comparison here.
When the Family First Prevention Services Act (H.R.253) was passed, it recognized that the best placement for children is in the least restrictive setting. This is also true for undocumented children in the custody of the Office of Refugee Resettlement (ORR).
In that regard, since 1997, the Flores Settlement Agreement has defined the rights of these children. In essence, it obligates the government to keep the children in the least restrictive setting and sets standards for their care. Recently, however, the Departments of Homeland Security (DHS) and Health and Human Services (HHS) have put forth a proposal to withdraw the agreement.
The agreement was never meant to be a de facto law so much as a framework, and in the original agreement there was a sunset clause expiring the agreement after 5 years provided the government implemented the terms of the settlement as federal regulation or Congress superseded it. Neither has happened. In fact, in 2015 the settlement was expanded to include all minors who come across the border without legal authorization (not just the unaccompanied ones who become custody of the federal government).
Despite the absence of the required federal regulation or congressional action, DHS and HHS have begun the process to withdraw the agreement. In doing so, families could be detained and placed in less regulated facilities, broadening the allowances for emergency loopholes for not meeting standards of care, and making it easier for government to revoke legal protections for unaccompanied minors.
This proposed rule change includes a comment period that ends November 6th, 2018 after which Judge Dolly Gee will determine whether the regulations are eligible to supersede the Flores Settlement Agreement. COA is urging interested parties to provide comments which put forth recommendations that emphasize the well-being of a child, and which ensure that migrant children receive trauma-informed and evidence-based care in the least restrictive setting.
The best practice of care for these children was established by the Flores Settlement Agreement and is contained in COA’s UC standards. It includes wraparound services to support their integration into society and placing them with kin or resource families in the most home-like settings. It has been two decades since the Adverse Childhood Experience (ACE) Study was conducted and the lessons learned have been indelible to the field: childhood trauma has long lasting effects. We cannot discuss the needs of this population without discussing the need for trauma-informed care.
So what can we do as human service professionals? Well, there are a few options:
- COA has put forth standards we consider best care for unaccompanied children. These standards are available our website. All comments and feedback will help shape the voice we provide DHS and HHS.
- Share your comments about what is best for children. Go to the Regulations.gov website for instructions on how to comment. Need some help with this? Here’s a resource to help you craft your response.
- Reach out to your representatives and ask what their plan is for the comment period and how they are defining proper care for unaccompanied minor children.
We are all impacted by government spending and regulations beyond our day-to-day work in human services. Regulations empower us as consumers to make informed decisions about our health and safety. They give us peace of mind as employees, that our employer’s practices will be fair and that public spaces will be clean and meet the necessary standards.
We put faith in our political representatives to advance regulation in order to improve the overall welfare of our society. Over time we observe reactive regulation created to address urgent events, gradual regulation to help move the needle on key issues across a country, and preemptive regulation intended to aid the success of future generations.
Let’s explore the role of government regulations and learn more about their value to human services:
Need drives change
First, let’s discuss a historic example of the need for regulation. In September 1982, 12 year-old Mary Kellerman of Elk Grove Village, Illinois, died after consuming a capsule of extra-strength Tylenol. Within a month six more people in the vicinity would be dead and over 100 million dollars’ worth of Tylenol would be recalled from shelves across the United States. These instances amounted to what would be known as the Chicago Tylenol Murders.
The still unidentified perpetrator was purchasing Tylenol in the Chicago area, adding cyanide to the capsules, and returning them to the store. In turn the store was restocking shelves with the returned product and those that purchased and ingested the Tylenol died within an hour of consumption. Johnson & Johnson, maker of Tylenol, distributed warnings to hospitals and distributors and halted Tylenol production and advertising. Police drove through the streets of Chicago using megaphones to warn residents about the use of Tylenol.
In 1983, in response to the incident, Congress passed the Federal Anti-Tampering Bill, also known as the “Tylenol Bill”. The bill made it a federal offense to maliciously cause or attempt to cause injury or death to any person, or injury to any business’ reputation, by adulterating a food, drug, cosmetic, hazardous substance or other product. It also created a FDA requirement that all medications be sold in packaging with tamper-resistant technology.
In the face of a terrifying public safety situation, urgent government regulation was able to ease fears and create a foundation for the way medication is regulated in the U.S. today.
Regulation and our families
An example of regulatory oversight within the human services field is the passage of the Family First Prevention Services Act (FFPSA) by the U.S. Congress in 2018. It marks the largest reform of child welfare financing that has occurred in the past decade. The goal of the child welfare system is to keep all children and youth safe. The regulatory and spending path to deliver that safety has forever been changed because of this legislation.
Today it would be rare to find a human services professional that does not feel the primary initial goal for child placement is reunification with a parent or family member. Acknowledging that to keep kids safe in the long-term we must support families and alleviate issues that may lead to unsafe conditions/removal is widely accepted as best practice. The passage of FFPSA codifies this practice into law and allows funds to be used for family strengthening/preventative practices in child welfare agencies. This is a shift from exclusively funding out-of-home placement, which somewhat incentivized and eased this type of placement.
Though the enactment of FFPSA is a giant leap forward for the field, requiring some states and agencies to change decades of practices and redefining the way we regulate and implement a government program, the overall goal remains the same: to keep all children and youth safe.
Accreditation, a piece of the regulatory puzzle
Accreditation standards serve as a vehicle to implement and verify best practices. COA accreditation is recognized in over 300 instances across the US and Canada as an indicator of quality. In some cases the journey towards accreditation is due to a mandate, which is when states require that certain types of organizations become accredited. Another motivation for seeking accreditation might be due to deemed status, which is when state licensing bodies allow service providers to provide proof of accreditation in lieu of undergoing certain parts of the licensing process. The practice of states/provinces recognizing accrediting bodies is one way that they implement regulation, oversee services, and work to increase quality of services. We recommend checking out the blog post, Help! I’m Mandated! Now What? Choosing an Accreditor to learn more about navigating this topic.
Over time standards are updated to reflect advances in the field, changes in research and practice, quality indicators, and shifts in government regulation. Throughout an organization’s accreditation cycles they are able to evolve with these changes. Accreditation requires that organizations engage their stakeholders, creating an environment for services to adapt alongside the needs of the community. This relationship between accreditors, regulators, and service organizations builds a foundation for continuous quality improvement for both entities, improving outcomes for the clients served.
Instead of approaching government regulations as just another requirement, step back and imagine how they can assist with meeting your organization’s mission. How can these directives support your long-term goals or bolster best practice? As outlined through these examples, regulation is often born out of necessity. These rules can determine a health outcome, the safety of and access to medication, and the path for a child in foster care. At times regulation might seem like another hoop to jump through but in fact it can be a valuable component to your quality assurance toolkit.