ACF Releases IM on the Monitoring and Oversight of Psychotropic Medications

The Administration for Children and Families (ACF) sent an Information Memorandum (IM) to State and Tribal entities responsible for administering or supervising the IV-B and IV-E programs. The passage of the Fostering Connections to Success and Increasing Adoptions Act (FCSIAA) of 2008 required State and Tribal agencies to develop a plan for ongoing oversight and coordination of health care services for children in foster care. The Child and Family Services Improvement and Innovation Act strengthened FCSIAA by requiring that the plan include an outline of protocols for the appropriate use and monitoring of psychotropic medications. It also requires that the health care oversight and coordination plan outline how health needs identified through screenings will be monitored and treated, including emotional trauma associated with a child’s maltreatment and removal from home.

ACF contends in their IM that they have always encouraged title IV-B agencies to address oversight of psychotropic medications in the plan for ongoing oversight and coordination of health care services, which was only recently made a statutory requirement by the Child and Family Services Improvement and Innovation Act. The IM serves as a resource to States and Tribes as they develop protocols for the appropriate use of psychotropic medications in their IV-B plans, which will be required for their Annual Progress and Services Reports (APSRs) due by June 30, 2012.

In the IM, ACF outlines some practice guidelines related to the use of psychotropic medication for youth in care, specifically the guidelines developed by the American Academy of Child and Adolescent Psychiatry and the American Academy of Pediatrics. These efforts shed light on the prevalence of physicians responsible for prescribing psychotropic medication to foster children that have little to no formal training in child and adolescent psychiatry and who may not have experience dealing with the specific challenges of children in foster care, including but not limited to exposure to trauma and other untreated issues. The IM also includes two published guidelines that describe components of comprehensive oversight and management plans for children in child welfare.  These include an AACAP position statement and guidelines developed by an expert panel convened by the Reach Institute. In addition, a 2010 survey of State written policies and guidelines related to the oversight of psychotropic medication in foster children identified 10 key components of State oversight protocols, and a 2007  study provides additional considerations concerning consent, oversight and policy issues. All of the guidelines referenced above include the need for policies to contain provisions that encompass comprehensive and coordinated screening, assessment, and treatment plans; informed and shared decision-making; effective monitoring; availability of diverse mental health expertise; and means for accessing and sharing mental health and trauma-related interventions.

The IM concludes with a list of federal initiatives to encourage the appropriate use of psychotropic medication including multiple opportunities for information-sharing and technical assistance prior to the June 30th APSR due date. The IM also mentions the related Program Instructions issued by the Children’s Bureau which provides further guidance on required APSR content. In August, the Administration for Children, Youth, and Families, in collaboration with the Substance Abuse and Mental Health Services Administration, and the Center for Medicare and Medicaid Services will convene a two-day meeting with state level child welfare, mental health, and Medicaid authorities to work together to further strengthen oversight and monitoring by learning from each other. Beyond the upcoming activities, the U.S. Department of Health and Human Services will continue expanding the evidence base by funding research and demonstration projects that investigate both client-level interventions and system strategies to improve well-being outcomes for children and families.  Finally, ACF announced a forthcoming IM on Promoting Social and Emotional Well-Being for Children and Youth Receiving Child Welfare Services which will provide States, Territories and Tribes more information on the effects of childhood trauma and ways to promote social and emotional well-being.

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