Using Federal Funds Effectively
Entitlements and Permanent Authorities
Whichever system of merging funds is adopted, it is important to understand
fully the rules that govern the financing of services through federal programs
and use them in the most advantageous ways. The interviewees urged system planners,
when designing a sustainable funding strategy, to consider different ways of
using two categiories of federal programs:
- ongoing funding streams such as block grants or entitlement programs
that provide resources year after year in a reliable fashion, and
- discretionary
grants, which are time-limited and often require state or local matching
funds.
No state or local system of care can be sustained effectively without
ongoing financial support from both state/local and federal sources using
reliable funding streams. This means that the first and most important step
for
planners is to review federal programs that provide ongoing support without
arbitrary
federal time limits. Such programs exist to fund the activities of all
core child-serving agencies. For example:
- Medicaid supports all agencies—mental
health, child welfare, education and juvenile justice.
- Programs under
the Individuals with Disabilities Education Act, the Elementary and Secondary
Education Act and Vocational Education Act
are available
to school systems.
- Department of Justice Juvenile Justice and Delinquency
Prevention Act programs can support a wide array of activities.
- Title IV-B
and Title IV-E of the Social Security Act provide resources to child
welfare systems.
- The mental health, substance abuse and Maternal and Child Health
block grants fund specific services through three state agencies.
- Temporary Assistance for Needy Families (TANF) pays for services for low-income
families.
- The Social Services block grant (Title XX) funds a range of
services for many children.
The Bazelon Center has prepared a matrix that offers
an overview of the services and other activities that can be funded through
these and other
major
federal
entitlement or
block grant programs. All programs in this matrix provide
ongoing resources without
arbitrary time-limits, although the level of funding available
may vary, depending on federal appropriations and the state
and local
resources available to provide
a match.
The matrix is intended as a guide to specific opportunities
for funding services and activities with these federal programs.
Each program
has its own restrictions
on eligibility and on what can be funded, but it is impossible
to show such level of detail in a chart. For example, Medicaid
is shown
as
funding both
therapeutic foster care and supported housing. However, Medicaid
will fund only some of these activities’ costs (those
related to services) and not others (such as rent or reimbursement
to a foster family). Title IV-E funds
certain expenses, but only when children are in foster care
and only if costs are built into the foster care rate. Each
program in the matrix, similarly,
has limitations. Table 1 presents
a few of the most important caveats regarding these programs.
Interviewees
strongly recommend that to use these programs
effectively, states and, to a lesser degree, localities should
charge individual
staff with the
task of becoming experts on federal rules. Without a full
understanding of federal program rules and what can be done
with particular
federal funds, significant opportunities to support the system
of care
with federal resources
may be lost.
Given the complexity of many federal programs, this is most
effectively done
by a team consisting of staff from all relevant agencies.
The matrix identifies the potential of the various funding
streams
and can
facilitate such work.
The first several lines of the matrix
identify key aspects of eligibility rules, and can help planners identify
whether:
- the program is means-tested, meaning that program eligibility
is tied to family income and/or resources;
- only children
and youth of a certain age range are eligible. Programs where no such
limit is indicated may nonetheless
define the end of
childhood differently,
such as at age 18, 20 or 21;
- children must have a certain
level of impairment or disability before they can qualify for the program;
or
- other eligibility criteria exist, such as being in
foster care.
This allows system planners to see how
certain children may qualify for some services through one program and
other services
through
another. It thus
shows planners which services are not adequately
supported by federal sources and
where alternative funding approaches will be needed.
The
matrix also shows the services and activities that can be funded for eligible
individuals under
each of
the listed
federal
programs.
These are
grouped into:
- screening and assessment;
- services for children and families (medical
and clinical services are shown first, followed by
rehabilitation and support services);
and
- infrastructure funding (training, transportation,
etc.).
Because this matrix is for use by interagency
systems of care serving children whose mental
health care
needs have
already
been identified,
it does not
include the preventive programs that have a
broad population-based public health approach.4
The
matrix is based on federal rules governing the use of funds and on state
efforts to fund
specific mental
health services
or activities
through
the
programs. With respect to Medicaid, services
checked include those incorporated in a
number of states’ definitions of rehabilitation
services, even though, because of Medicaid’s
reliance on state flexibility, there may
be no federal rules defining these services.
Action step: The interviewees suggested that states set up a review
process to consider the services they wish to fund and the eligibility
status of the group of children they intend to serve, and to identify
existing budget assets. The matrix can then be used to identify gaps
in their current use of potential federal funding sources. |
To replicate this matrix at the state level—to show what is now funded
through these various federal sources—key
information is needed on who is eligible,
who can provide services, how
funds must be accounted for, and
what are the administrative requirements.
Administrative requirements include the rules
on reimbursement (prospective
and retrospective), reporting requirements
and more. It is also important to identify
the state and local agencies that can draw
down funds from the various
federal programs.
Interviewees suggested that
one way to gather information is to send
a questionnaire to
agency personnel
and to families, asking
what
works well
in the current
system of mental health service delivery
and what does not. This can help identify
services
that
require expansion
and
those viewed
by key
players
in the system
as not helpful.
Once the funding for various
services and activities is mapped, it is then possible
to engage in
a meaningful process
to
identify opportunities
in
the major federal programs by matching
the funding stream to the programmatic goals
of the system
of care. It is
also important
to consider how programs
can work
together to fund particular services. For
example, Title IV-E can
fund room
and board for therapeutic foster care while
Medicaid can fund training and services
for the therapeutic
foster family.
Such a comparison can also
help states develop a strategy to divert residential-service
spending to
community
care. Over
the years,
a number of states have found
this an important tool for improving
systems. Recently, New Jersey, as part of its
statewide child services reform, was
able to leverage federal funds for residential
services
that had
been 100-percent
state-funded. This enabled
dollars previously
used for long-term residential care to
serve
as the state Medicaid match in order
to extend the
array
of services
provided through
local community-care
organizations. As a result, children
and families have access to
a more diverse array of appropriate,
individualized community-based services.
Part of this process should be the
identification and removal of state and local barriers
to tapping into
federal resources
in appropriate
ways. The
end result should be a coherent set
of policies that allows programs to work
together as much as is feasible under
federal law.
In some cases, this may require
changing state rules and regulations
or even
state statutes.
You need the skill to identify rules
you can change. Then change those
rules you
can through
legislation,
policy
bulletins or
whatever. It’s a skill
to identify what you can change
and what would be wasted energy.
(State
mental health official)
Those interviewed stressed that, while
addressing all state-created barriers
at once may not
be manageable, states should begin
this process by dealing
with the most problematic constraints.
It is important to drop rules when
they are out-of-date. (State mental
health
official)
Interviewees stressed that the process
of removing program barriers and
simplifying rules should
not diminish accountability.
Instead,
the aim
is to create flexibility
and improve continuity of funding
for systems of care. Systems of
care should
adopt appropriate
performance measures to
measure their
outcomes.
How States Use Federal
Entitlement and Block Grant Funds
Without exception, interviewees
had found Medicaid to be the
backbone of their funding strategies. Although
federal Medicaid law allows states
to fund a
wide range of services, the interviewees knew that in many states either
the state Medicaid agency or the federal regional office resists efforts
to take full advantage of federal options. But not all states are so reluctant.
New Jersey’s representatives described a strategy where several state
officials—including those from the state Medicaid agency—went
to the federal regional office to explain their plan for funding community
mental health services for children, showing how it would make services
more accessible and improve child outcomes. Federal approval of most of
the state’s
Medicaid proposals followed.
A second significant yet often underutilized federal entitlement for children
with mental and emotional disorders is the Individuals with Disabilities
Education Act (IDEA). The IDEA funds services for children of all income
groups and is
thus a critical adjunct to Medicaid funding. In Vermont, negotiations with
the education system have led to school systems’ contributing to
the state Medicaid match in order to support more than 300 school-based
clinicians.
Mental health centers provide significant backup once children are identified
under the IDEA.
Child welfare resources are typically used to fund room-and-board
costs for children in care (Title IV-E) or to support adoption and reunification.
Federal
funds for prevention of out-of-home placements (Title IV-B) are much
scarcer, but the rules are very flexible as to the range of services that can
be
funded and more flexible than Title IV-E regarding the low-income children
who can
be targeted.
Juvenile justice funds flow in large formula-grant programs
to states, which must funnel most of them to localities. As the matrix shows,
very
few restrictions
are placed on the use of these funds for children with mental or emotional
disorders. However, mental health and other eligible activities often
compete for these funds locally. Ultimately, juvenile justice typically
provides
fewer dollars to a system of care than mental health, child welfare
or Medicaid, but these funds can be used for activities other federal sources
will not
support.
Discretionary Programs Plug the Gaps
Interviewees reported using a number of federal categorical programs for
children’s
services to strategically supplement funds from entitlements and block grants.
They suggest that states review the most relevant categorical programs to
determine whether these dollars can fill gaps in funding of a particular system
of care,
provide start-up money for new services, underwrite infrastructure, support
training or retraining, or finance strategy-planning processes.
Major discretionary programs authorized through each of the four core child-serving
federal systems (mental health and substance abuse, child welfare, education
and juvenile justice) are shown in Table 2. This
is not a definitive list, but a listing of programs considered most relevant
and useful
by the
officials who participated in the Bazelon Center study. Most of these programs
are funded by the Department of Health and Human Services—particularly
the Substance Abuse and Mental Health Services Administration—but
the Departments of Education and Justice are also important sources to
which state
and local systems can look for discretionary funds.
Because it is important not to rely too heavily on discretionary programs
that will inevitably end within a prescribed number of years, one strategy,
according
to those interviewed, is to use such programs to initiate the most critical
services missing in the current system. In some cases, a federal entitlement
program may pay for the service once it is in place, but it will not
pay development costs. In other cases, once demonstrated effective, such services
may be more
readily funded through state or local sources. In adopting this approach,
it is important to develop a strategy for how a reliable funding stream
will eventually
pay for the services or activity once discretionary funds are terminated.
Other activities that can often be best funded through federal discretionary
programs are time-limited, such as planning, technical assistance,
training or building data infrastructure.
Such time-limited activities can also be funded with private resources,
such as grants by national and local foundations, corporations and
community organizations.
The interviewees pointed out that, while private grants or contributions
provide lower funding levels than most government sources, they can
be extremely flexible
and therefore valuable to system planners.
Those interviewed saw many opportunities for states and localities
to use federal programs to fund an expansive array of services
for children
with
mental disorders
who receive services through various child-serving systems. However,
these funds will be more efficiently used if the core child-serving
agencies collaborate around both service delivery and funding issues.
The remainder
of this report
reflects the perspectives of these officials with respect to forging
meaningful
and long-lasting cross-agency collaborations better to meet children’s
mental health care needs.
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