Prevention Services are services eligible for federal subsidies under Title IV-E of the Social Security Act. Offered by Child Protective Services (CPS) agencies directly (or more commonly, by 501(c)4 non-profit social service agencies contracted by CPS), prevention services are, at least in theory, designed to prevent out-of-home placement (foster care, kinship care, institutionalization, etc.) of child(ren) when CPS identifies safety concerns and either the reasonable efforts requirement doesn’t apply or reasonable efforts have been made and despite them, CPS still determines there is reasonable cause to believe that the child(ren) are in immediate or impending danger of harm (this is when prevention services must be offered; prevention services are often offered as part of the alternative response or even in cases where the allegations are unsubstantiated). Unlike services where CPS refers externally, these services are always provided in-home and at no cost to families (they’re paid for by CPS with a combination of federal and local agency funding). This begs the question: what actually constitutes a prevention service?
A prevention service is any service intended to prevent out-of-home placement that has been formally approved by the federal government to be subsidized for such purposes under the terms set forth in the Family First Prevention Services Act. Once a particular intervention is approved by the federal government as a prevention service, it gets placed on an official list known as the Title IV-E Prevention Services Clearinghouse. While Prevention Services are determined to be evidence-based, it’s not clear how evidence-based is defined (other than there is published empirical research to support it) or whether the standard is applied consistently.
Most services on the Title IV-E Prevention Services Clearinghouse list do not have strong evidence supporting their efficacy and when first placed on the list, are in effect experimental. Evidence to support them is gained by using them in practice to preserve or reunify families with CPS involvement. This data is then published in empirical journals. In fact, only about half of all services listed have an evidentiary rating of promising or better; the rest have no evidentiary rating at all!
The availability of prevention services varies, and most locales only offer certain services on the list, rather than all. In a CPS case, which prevention service (if any) may be offered depends on a few factors:
- The prevention services currently made available by the local CPS agency or its contractors in the vicinity of the case address.
- The number of slots available (there is a limit to how many clients in one geographic area may be able to be served). This is based on the number of contractors providing each service, the maximum caseload each provider can handle and the demand in the geographic area (, borough, city, county, etc).
- The safety concerns identified.
Most CPS front line staff (these are the staff the families communicate with: usually CPS investigators or foster care case managers) are unaware of the Title IV-E Prevention Services Clearinghouse and are unlikely to be involved in prevention service selection (prevention service selection is usually left to another employee whose sole job is finding an available slot in a [reasonably] relevant prevention service available in the vicinity of the case address). They do not know what, if any, evidence there is to support the service they’re recommending, so it’s up to you to understand this and make an informed decision. At Heartwork Defense, we tend to recommend against accepting prevention services at all and instead finding your own equivalent provider outside of the prevention services context (known as Community-Based Organizations) for a few reasons:
- Prevention service providers are either contractors or CPS employees. Since CPS pays for the services, the relationship between the prevention services providers and CPS is closer than it otherwise would be (read the contract carefully!).
- Prevention service providers are mandated reporters paid by CPS and if they fail to report even small concerns to CPS and something happens, they could lose the contract. Therefore, prevention services providers are among the most aggressive mandated reporters and among the top reporters of subsequent cases. As a reminder, most prevention services are provided in-home- meaning prevention services providers visit your home on a regular basis (anywhere from 1-5 times per week or more).
- There are many quality services in the community that are either free or covered by Medicare/Medicaid and most commercial (individual or employer-sponsored) health insurance plans that serve the same purpose without the connection to CPS.
Prevention services and the Family First Prevention Services Act are marketed as the solution to avoid foster care and keep families together. However, a careful look at the Title IV-E Prevention Services Clearinghouse in design and implementation raises serious concerns over service quality, service specificity, parental rights and surveillance. Ultimately, the following question, which should send chills down every parent’s spine, is posed: who’s child(ren) are they?