FFT Service Definition: 

 The definition doesn’t seem to align with the model and different the Blueprints or the FFT website.  Is it possible to highlight the family and relational component and capture a definition that will capture the wide range of referral sources?  Suggested language or example captured below.

Functional Family Therapy (FFT) is a short-term, evidence-based treatment program for youth (ages 11-18 years old) to address a range of emotional or behavioral problem.  Referrals for the treatment may including co-occurring substance use disorders, recommendations by the juvenile justice, behavioral health, school, or child welfare systems. Youth falling outside this age range may be evaluated on an individualized basis for appropriateness of treatment and eligibility under EPSDT guidelines. FFT is a family intervention that addresses both symptoms of serious emotional disturbance in the identified youth as well as parenting/caregiving practices and/or caregiver challenges that affect the youth and caregiver’s ability to function as a family. The FFT model is a rehabilitative service that serves as a prevention/ diversion/ intervention or step-down from higher levels of care and seeks to improve within-family attributions, family communication, and supportiveness while decreasing intense negativity and dysfunctional patterns of behavior.

 Critical Features & Service Components.

This section appears a little redundant, especially as they are expanded in the following page, consider deleting the first 5 bullets and replace these with: FFT consists of five major components: engagement, motivation, relational assessment, behavior change and generalization (explained in more detail below). Each of these components has its own goals, focus and intervention strategies and techniques.

The description appears to get very specific, this section appears to be a sample scenario or individual case example:  “…assess family behaviors that maintain problem behaviors, modify dysfunctional family communication, train family members to negotiate effectively, set clear rules about privileges and responsibilities, and generalize changes to community contexts and relationships)…. 

Can the covered services (page 21) also include Staff Supervision and consultation (individual and group) or Pre-engagement interventions.  Are there any cases in which travel or milage could be covered if not billed in a daily per-diem, for rural cases? 

Service Limitations (page 21 and 22)

Can you provide clarity about the Covered Services including Crisis Intervention?  While it can (which is clearly stated) it shouldn’t preclude the use of Crisis services, if needed.  The combination of Crisis Stabilization and FFT could be a very useful combination for a brief time period. Can there be exceptions to overlapping services if there is medical justification for two services to exist co-currently to prevent a higher level of care? Seems that family receiving FFT may need additional IIH or crisis supports during the initial phases or if a youth escalates during services. Can there be exceptions?

 Required Activities (page 21) 

Can an assessment or evaluation recommending the service be accepted to prevent duplication of assessments?  For example, if a psychological or SA evaluation occurred and recommend the service, does the FFT Supervisor need to duplicate the assessments?

Provider Qualifications

FFT professionals maintain a minimum caseload of 5 cases at any given time (20 hours per week) and an average of no more than 10 to 12 cases at any given time. How can this indicate a GOAL of 5, but still account for changes to capacity, utilization, team size, location, team phase, experience and other variations (i.e. ramp up time, new staff, growth, etc.)? 

New Team vs Established Team– can this new and established team description align with FFT’s status definition?  Suggest adding a caveat that if the team “restarts or pauses – if there is a full turnover of staff and supervisors etc…  

How will teams that cross agencies be addressed?  For example, a cross-agency team (e.g. a single team has staff from numerous agencies) how does the licensure and billing get addressed?   E.g. An established team adds staff from another agency and they bill separate from the Team lead, are they a new or established team?

Staff requirements:

Per the draft, the site supervisor is required to carry a caseload (Can we remove the minimum requirement of five active cases at all times?  While that is the goal, what happens if utilization of the team dips?), while also attending FFT supervisor trainings, assuming supervision of the team, attending consultation with a FFT national consultant, completing FFT supervision paperwork and providing ongoing review of the client service system.

Consider removing the details about team phases – year one, two and three: the language could be simplified to indicate staff must participate in FFT model training and weekly supervision.  (This language gets a little confusing and appears too detailed based on years, rather than the FFT Team phases).     

REMOVE: After the first year, this frequency moves to two times per month for one hour each, and onsite FFT supervisors receive phone or web-based consultation to assist in providing consultation on cases and ongoing focus on the FFT model. In year three, the supervision is focused on supporting the team and they have one call per month with the supervisor and the FFT national consultant. The FFT team is required to complete ongoing continued trainings to maintain their certification….

Consider adjusting the 33% to indicate an ACTUAL number of clinicians i.e. 2 FFT Professionals.    FFT Professionals on a team may include LMHPs, LMHP-Rs, LMHP-RPs, LMHP-Ss and two team members may maintain following credentials QMHP-Es, QMHP-Cs, CSACs and CSAC- supervisees.   Suggest removing the 33%.  Or can there be additional language that clarifies the intended vs actual team size.  Or is there guidance about staffing credentials and time to hire or re-hire new staff?   

Can you provide clarity around “Assessments”?  FFT incorporates assessments as part of the model which do not require LMHP status – outside of the Certified Needs Assessment?

Consider removing the final paragraph, as it summarizes FFT services and duplicates the role and definition of FFT Professionals:  Therapeutic interventions, crisis intervention and care coordination for FFT must be provided by a LMHP, LMHP-R, LMHP-RP, LMHP-S, QMHP-E, QMHP-C, CSAC or CSAC-supervisee who meets the qualifications of this section.

Admission Criteria

#2 Why are services limited to such a specific diagnosis (primary diagnosis categories of disruptive behavior, mood, or substance use disorders)?  Can there be allowances for approvals outside of these diagnosis?  Has FFT provided these limits or are there ways to authorize services outside of the three groups of disorders?

 # 3 – adjust the final bullet into – two sperate bullets as follows:

• The youth is adjudicated and placed on probation or parole. 

(Currently FFT is an identified treatment need based on the court service units recommendation which may include DJJ’s YASI assessment and/or included on the DJJ case plan to meet the needs of the court and the RSC process – but allowing probation or Parole would help capture these youth)

• The youth is returning home from out?of?home care (e.g. juvenile detention, commitment, treatment foster care, emergency shelter, inpatient acute hospitalization, residential crisis stabilization, or residential treatment, etc.) and FFT is needed as step down service from an out of home placement;

Consider  Modifying #6 to require a semi-permanent or permanent family/caregiver identified, residing in the same home as the youth, and available to participate in this intensive intervention (or exclusionary criteria that prevents temporary or absent caregiver.

Consider Removing # 8 -  There is an order through juvenile justice for participation in community-based treatment and the youth meets the other medical necessity criteria.  We would like to avoid court orders for mental health services.

 Functional Impairment

QUESTION:  what are FFT professional appointments, and what is therapeutic mentoring – is this defined anywhere within DMAS manual?

Can a SA Case Manager be a possible referral source also?  (included with the support of a MH Case Manager, SA Case manager or TFC Case Manager)

 Booster sessions: 

Booster session may occur, if referring behaviors re-emerge.  Boosters are not appropriate if there is a change in caregiver, or significant household relationships (at which point a new dose of FFT may be explored).  Suggest removing the language: “If the youth is not actively involved in another level of behavioral health treatment”  Booster sessions may help align the new BH service to the skills learned and it would it occur within the 14 days that are allowed for transition