18.3 Prevention of Unnecessary Placement (PUP)

Georgia State Seal

Georgia Division of Family and Children Services
Child Welfare Policy Manual

Chapter:

(18) Support Services to Preserve or Reunify Families

Policy Title:

Prevention of Unnecessary Placement (PUP)

Policy Number:

18.3

Previous Policy Number(s):

N/A

Effective Date:

March 2020

Manual Transmittal:

2020-03

Codes/References

Title IV-E of the Social Security Act §§ 431 (a) (1) and (2)
Public Law 96-272 Adoption Assistance and Child Welfare Act of 1980

Requirements

The Division of Family and Children Services (DFCS) will:

  1. Explore community-based services, Medicaid covered services, Promoting Safe and Stable Families (PSSF), services offered through partner agencies such as Department of Behavioral Health and Developmental Disabilities (DBHDD), Department of Community Health (DCH), Department of Public Health (DPH), and other resources at no cost to the family before using PUP contracted services.

  2. Determine eligibility for PUP services based on the following criteria:

    1. The family is involved in Family Support Services, Family Preservation Services, Investigations, or Permanency.

    2. One of the following conditions exist and is documented in Georgia SHINES:

      1. Risk of Imminent Placement

      2. Immediate Reunification

    If PUP funds are used in Family Support Services document how the use of the funds will ensure child safety and prevent future involvement with DFCS.
  3. Offer PUP services to eligible families in accordance with criteria outlined in the COSTAR manual (also see Practice Guidance).

    Refer to the COSTAR manual for fee schedules, contract requirements, funding limitations and applicable waivers.
  4. Prohibit the use of PUP funds for the following services:

    1. Payment of consumer credit debt

    2. Purchase of trailers or down payment on trailers, trailer lot, or homes

    3. Legal services for separation or divorce

    4. Custody modification or modification of visitation

    5. Purchase or down payment on vehicles

    6. Repairs on rental property

    7. Traffic fines/Court costs

    8. Ongoing sexual abuse offender counseling for an adult (cost is paid by the offender)

  5. Have an approved Service Authorization and contract with a provider before incurring costs for any direct client services. Document in the summary section of the Service Authorization how the family will manage after the provision of PUP services.

  6. Document the need for PUP services and the desired outcome in the Safety Plan or Case Plan in Georgia SHINES.

  7. Monitor service provision to ensure the family is receiving services based upon their identified needs and that behavioral changes are occurring as a result of the services, as applicable.

  8. Document provision of PUP services in Georgia SHINES within 72 hours of occurrence or receipt of provider notes from the service provider. Update the case plan if services are provided pursuant to a case plan.

  9. Monitor PUP services and expenditures in accordance criteria outlined in the COSTAR manual.

  10. Ensure providers and staff respect families’ rights to confidentiality and protected health information through adherence to the Health Information Portability and Accountability Act (HIPAA) and other confidentiality laws in accordance with policy 2.5 Information Management: Health Insurance Portability and Accountability Act (HIPAA) and 2.6 Information Management: Confidentiality/Safeguarding Information.

Procedures

Social Services Case Manager

  1. Determine the family’s eligibility for PUP services based on the needs of the family and the established eligibility criteria.

  2. Assess the family’s financial status to determine whether:

    1. Any other resources are available prior to utilizing PUP funds;

    2. The family can contribute to the payment needed;

    3. How the family will manage after the provision of PUP services.

  3. Determine the amount of PUP funding the family needs.

  4. Complete a Service Authorization in Georgia SHINES and obtain approval to initiate PUP services in accordance with the Georgia SHINES Job Aid: Comprehensive Job Aid for Service Authorization in Forms and Tools. Document the provider’s acceptance of the referral in Georgia SHINES.

    Emailed referrals must be encrypted. To encrypt the email, type DHSEncrypt in the Subject line.
  5. Document the need for PUP services and the desired outcome in the Safety Plan or Case Plan in Georgia SHINES.

  6. Review and upload provider reports/summaries in Georgia SHINES within 72 hours of receipt. Also upload any accompanying documents (i.e., bills, receipts, letters) to External Documentation. Update the case plan with services provided, as applicable.

  7. Re-evaluate continued authorization and utilization of PUP funds at required case reassessment periods and document whether funds will continue to be used.

  8. Monitor and document service provision in accordance with policy 19.17 Case Management: Service Provision.

  9. Update the case plan in accordance with policy 8.3 Family Preservation Services: Case Planning or 10.23 Foster Care: Case Planning, if services are being provided in conjunction with a case plan.

Social Services Supervisor

  1. Assist the SSCM in determining if PUP services are appropriate.

  2. Review and approve the Service Authorization.

  3. Ensure timely completion and submission of the referral to the provider in accordance with policy 19.17 Case Management: Service Provision.

  4. Review documentation in Georgia SHINES to ensure services are being provided and the SSCM is providing appropriate follow up.

  5. Ensure services are monitored by reviewing provider reports/summaries, etc.

Practice Guidance

Prevention of Unnecessary Placement (PUP)

The goal of PUP services is to reduce risk factors contributing to child maltreatment in order to ensure the protection and safety of children. Imminent risk of placement or readiness for reunification of the children must be clearly documented in the case record. The PUP Program offers an array of support and intervention services. Through PUP, psychological or psychiatric assessments, substance abuse assessments, drug screens, and counseling services may be obtained from vendors who have the necessary skills and training to address the identified problems. PUP may also be used to help a family through a financial crisis with emergency rent, utilities or childcare.

Families are encouraged to contribute to the costs of needed services. A family’s own contribution, financially or in-kind, toward part of the required PUP expenditures is highly recommended, particularly in long term services such as childcare or counseling. This encourages and promotes a commitment on the part of the caregiver(s) to participate in the case plan toward goal achievement and self-sufficiency. PUP funds should not be used if other resources (i.e., community resources, private insurance or Medicaid) exist or until other resources have been exhausted.

Risk of Imminent Placement

Risk of imminent placement is defined as the likelihood of removal of children from their parent or caretaker and placement of the children into an emergency shelter or foster care placement within 14 days without intervention.

Immediate Reunification

A child must be in a foster care placement, including a kinship placement, and be ready for reunification with parents, kin, guardians or non-foster care placement within 60 days of initiating PUP services.

Emergency Housing/Financial Assistance

PUP funds may be authorized for temporary shelter, food, clothing and related services required by families with children to cope with a temporary crisis situation which poses an imminent threat to the safety of the children (i.e., fire, eviction, unsafe housing, separation for the safety of children and family members, etc.). It is important to assess how the crisis arose and how the family plans to manage going forward when considering the authorization of PUP funds for emergency financial assistance (i.e. rent and utility payments). If the family’s crisis is because of some unavoidable emergency, PUP can be helpful. If the family’s difficulties are chronic and reflect a lifestyle of crisis, PUP should not be used without a documented plan of how the family will manage once PUP is utilized. The case record must reflect how the family will resume responsibility for payment of rent and utilities after this one-time assistance. All financial assistance is through vendor payments.

The emergency housing/financial assistance and temporary childcare components of the PUP Program are not to be used as a county “general assistance fund.” These funds are provided as one support service among others as a part of the safety or case plan in an open child welfare case.

Past due rent, current rent and up to three months future rent can be paid once per family per fiscal year. Past utility bills, current utility bills and up to three months future utility bills may be paid once per family per fiscal year. Utility deposits may be paid once per fiscal year. When PUP funds are used to pay deposits for rent or utilities, the SSCM should include with the payment, a letter notifying the payee that the deposit should be returned to the County Department. Acceptance of this procedure by utility companies varies; however, SSCMs should still send the letter along with the payment. They should also notify the parent/caregiver that any deposits will need to be reimbursed to DFCS.

Minor home repairs, directly related to the risk of maltreatment, may be authorized. Repairs on rental property that are the responsibility of the property owner, landlord, and/or property Management Company are NOT allowable expenses under PUP.

Minor legal services or nominal legal fees may be paid with PUP funds, if it is directly related to risk of placement or immediate reunification efforts.

Emergency Furniture

PUP funds can be used to purchase emergency furniture after all other community resources have been exhausted. All emergency furniture assistance must be paid to the vendor only. Examples of emergency furniture include mattresses, cribs, and major appliances, etc. to maintain or reunify children back in a stable home. Prior authorization from the supervisor is needed before using this service.

Emergency Clothing

PUP funds can be used to purchase emergency clothing after all other community resources have been exhausted.

Temporary Childcare Services

Temporary childcare services may be purchased for families when the unassisted, daily care of children by their family presents an unacceptable risk of continued maltreatment and/or placement. Types of temporary childcare include:

  1. Group Day Care (State licensed, center‑based day care for seven to eighteen children).

  2. Family Day Care (State registered, approved family home day care for up to six children).

  3. Day Care Center services (State licensed, center‑based day care for nineteen or more children).

Childcare is often an ongoing need and PUP’s time-limited services cannot meet this ongoing need. The safety or case plan should indicate how the family will assume the responsibility for the ongoing expense of day care. Childcare is for children under the age of 13, or under the age of 18, if there is a physical or mental disability. Childcare services are provided away from their own home for less than 24 hours per day. The exception to this is payment of emergency 24-hour childcare with an approved resource when a caretaker is hospitalized and has no other resources to meet this need. The childcare services must correct or prevent a situation that would lead to an out-of-home placement of one or more children. Other support services such as Childcare and Parent Services (CAPS) should be accessed before approving PUP for temporary childcare.

There is a maximum of six months of childcare services provided to each child per family per fiscal year.

Counseling

Counseling may be authorized for families when the provision of counseling services will help the family or individuals within the family resolve issues that contribute to the risk of maltreatment and out-of-home placement. Types of counseling services that may be utilized include, but are not limited to the following:

  1. Individual

  2. Child

  3. Group

  4. Family

  5. Substance Abuse

  6. Marital Counseling

  7. Domestic Violence

  8. Anger/Stress Management

  9. Grief & Separation Management

  10. Behavior Management

  11. Trauma Focused Therapy

Counseling services through PUP are provided primarily to help with the effects of maltreatment and to strengthen the family’s ability to resolve their problems through effective decision-making and coping skills. The counselor shall adhere to the professional code of ethics regarding responsibility to clients, integrity, and confidentiality, responsibility to colleagues, assessment instruments, research, advertising, and professional representation. Services must be provided by an approved contracted provider.

Authorizing payment for Individual ongoing counseling for a sexual abuse offender is prohibited. The cost of ongoing counseling for a sexual abuse offender is the offender’s responsibility. PUP may be used to pay for the ongoing counseling of a sexual abuse offender, when the offender is a minor in the household, as a part of the reunification plan, and when such services will prevent the removal of other children from the home. All other resources to pay for treatment and counseling for the juvenile sex offender should be explored prior to use of PUP. Medicaid and private insurance should be used before the use of PUP funds.

Behavioral Health Assessment Guide

This guide is to serve as a minimum standard reference for mental health/behavioral health assessments. The Division of Family and Children Services understands that every client is different, and selection of specific tests and tools may depend on the needs of the client. The Division respects the autonomy of licensed psychologists and mental health professionals and their selection of assessment tools. This guide does not restrict assessors to the referenced components of each listed assessment. All Assessments should include:

  1. Demographics & presenting information

  2. Collateral information

  3. Evidence of records review

    1. Mental health history

    2. Medical History

    3. Previous legal/court involvement

    4. DFCS history

    5. Family history

  4. Evidence that several methods were used to assess the client

    1. Direct observation, interviews, formal questionnaires, norm reference tests,

  5. Summary of results and recommendations

The Division strongly recommends the use of best practice when conducting these formal assessments.

  1. All assessments should be completed in a setting that secures privacy

    1. Assessments should not be in a group setting

    2. All assessors should adhere to the HIPAA guidelines

  2. The Division supports the standards of the American Psychology Association (APA) applicable to mental health assessments and recommends licensed psychologists and licensed mental health professionals to adhere to those standards.

Assessment Type Summary/Definition Key Components

Psychosexual

Evaluates an individual accused of illegal and/or inappropriate sexual behavior.

  • Level of risk for sexual and non-sexual reoffending

  • Mental and emotional attitude concerning sexual activity

  • Risk factors

  • Client history of sexual abuse

  • Strengths and protective factors

Psychiatric/Psychological

Psychological evaluations are completed by licensed psychologists. Psychiatric evaluations are completed by psychiatrists and they can prescribe medication. Both evaluations use assessment tools alongside observations of behaviors to arrive at a diagnosis. These assessments measure an individual’s mental and behavioral health characteristics.

  • Summary of client’s cognitive functioning

  • Clinical diagnosis derived from the DSM. Diagnosis should be explicitly detailed specific to the client’s behavior

  • If medication is recommended, justification for the medication as well as side effects should be listed

Parental Fitness

A Parental Fitness assessment is a specialized Psychological evaluation, usually conducted by a licensed psychologist or psychiatrist. This assessment evaluates an individual’s ability to function as a parent. The evaluator assesses how a parent meets the minimum standard of acceptable parenting skill levels in order to protect their children.

  • Quality of parent-child relationship

  • Provide Parent’s lifestyle habits and psychological state that could affect the child’s safety

  • How parent responds to child’s health, educational, and developmental needs

  • How parents view and know their children

  • Attitudes towards parenting

  • Parenting strengths

  • Parenting beliefs

Neuropsychological

An assessment that reviews the health of one’s brain, brain patterns, and how it functions. Documents patterns of strengths and weaknesses among cognitive and behavioral functions. A neuropsychological assessment should only be completed by a licensed psychologist who is trained and specializes in completing a neuropsychological evaluation.

  • Assessment of an individual’s level of function including motor skills, memory, problem solving, decision making, and cognitive functioning

  • Identify if the client has suffered from a brain injury

  • Differential diagnosis and/or full DSM diagnosis

Domestic Violence

A risk assessment tool to evaluate an individual’s history of/with violence (emotional, sexual, physical, psychological, property) and likelihood of violence continuing to occur.

  • History of aggression/involvement in a domestic violence relationship

  • Child’s history of witnessing abuse

  • Discuss if mental illness is present

  • Identify the violent behaviors

  • Identify the triggers for violent behaviors

  • Explore safety of client and develop a safety plan if warranted

Substance Abuse

This evaluation determines if an individual is misusing or abusing substances. This tool assists in the development of a plan for recovery if one is needed.

  • Severity of addiction

  • Medical conditions that could complicate recovery

  • Readiness to change

  • Relapse recovery/current living environment

  • Triggers to substance use

Bonding/Attachment

A tool that assesses the quality of the relationship between the caregiver and the child.

  • The benefits of maintaining the placement

  • Assess for long-term effects of either decision

  • Identify the risks of disruption from current placement

  • Behavioral observation between child and caregiver and child with potential placement

  • Compare the bond between the child and the caregiver and child with potential placement

CCFA

A whole family assessment to evaluate multiple, complex, sometimes intergenerational problems that threaten the stability and overall functioning of current and future generations within a family unit.

See DFCS policy for key components

Drug and Alcohol Screens

PUP funds may be used to obtain drug and/or alcohol screens for the purposes of determining caregiver substance abuse and/or monitoring compliance with case plan goals related to substance abuse. Drug/alcohol screens must be completed by an approved contracted provider. Drug and/or alcohol screens should be conducted at random by the designated service provider.

Paternity/DNA Testing

PUP funds may be utilized for Paternity/DNA testing in cases where prevention of placement or reunification is related to establishing paternity with a non-custodial parent. Paternity testing may also be authorized during the TPR process.

Safety/Enrichment Activities (children in the custody of DFCS only)

Enrichment programs promote the well-being of children by providing them with an experience that draws out their fullest potential and talents. Enrichment activities are often geared towards an educational experience that focuses on high abilities such as gifted programs and can span across the arts, humanities, and sciences. They help bolster academics and social interactions for children. These extra-curricular activities can include, but are not limited to:

  1. Dance Classes

  2. Art classes

  3. Sports

  4. Band

  5. Advanced Reading or Math courses

Funding for this service can also include purchase of materials needed for these classes (i.e. instruments, uniforms and equipment, supplies, etc.)

Children must be under age 14 and funds are available for all children in DFCS custody; regardless of the placement type (DFCS FH, kinship placement, CPA).

  1. ILP Program (UAS 585) may be used for children over age 14 that are ILP eligible.

  2. Afterschool Care may have services available for children under the age of 13.

Forms and Tools

N/A