State Part C Agencies and the Child Abuse Prevention and Treatment Act CAPTA

1. State Part C Agencies and the Child Abuse Prevention and Treatment Act (CAPTA) Aubyn C. Stahmer, Ph.D. Rady Children’s Hospital Child and Adolescent Services Research Center Collaborators: Danielle Thorp Sutton, PhD., Lise Fox, PhD. and Laurel K. Leslie, MD, MPH Contact Information Aubyn C. Stahmer, Ph.D. Danielle Thorp Sutton, Ph.D. Rady Children’s Hospital Autism Spectrum Assessment and Treatment Clinic Child and Adolescent Services Research Department of Psychiatry and Behavioral Medicine Center Silver Child Development Center, USF 3020 Children’s Way MC 5033 3515 E. Fletcher Ave., Suite E (MDC 102) San Diego, CA 92123 Tampa, FL  33613-4706 astahmer@casrc.org dsutton@health.usf.edu Laurel K. Leslie, M.D., M.P.H. Lise Fox, Ph.D. Center on Child and Family Outcomes Department of Child and Family Studies Institute for Clinical Research and Health Louis de la Parte Florida Mental Health Institute Policy Studies University of South Florida, MHC 2113A Tufts-New England Medical Center 13301 Bruce B. Downs Blvd. 750 Washington Street, Tufts-NEMC #345 Tampa, FL  33612-3807 Boston, MA  02111 fox@fmhi.usf.edu LLeslie@tufts-nemc.orgContact Information Aubyn C. Stahmer, Ph.D. Danielle Thorp Sutton, Ph.D. Rady Children’s Hospital Autism Spectrum Assessment and Treatment Clinic Child and Adolescent Services Research Department of Psychiatry and Behavioral Medicine Center Silver Child Development Center, USF 3020 Children’s Way MC 5033 3515 E. Fletcher Ave., Suite E (MDC 102) San Diego, CA 92123 Tampa, FL  33613-4706 astahmer@casrc.org dsutton@health.usf.edu Laurel K. Leslie, M.D., M.P.H. Lise Fox, Ph.D. Center on Child and Family Outcomes Department of Child and Family Studies Institute for Clinical Research and Health Louis de la Parte Florida Mental Health Institute Policy Studies University of South Florida, MHC 2113A Tufts-New England Medical Center 13301 Bruce B. Downs Blvd. 750 Washington Street, Tufts-NEMC #345 Tampa, FL  33612-3807 Boston, MA  02111 fox@fmhi.usf.edu LLeslie@tufts-nemc.org

2. CAPTA 2003 States receiving CAPTA funds must develop and implement “provisions and procedures for referral of a child under the age of 3 who is involved in a substantiated case of abuse or neglect to early intervention services funded under part C of the Individuals with Disabilities Education Act” [106(b)(2)(A)(xxi)].

3. IDEA 2004 States must provide “a description of the State policies and procedures that require the referral for early intervention services under Part C of a child under the age of 3 who is involved in a substantiated case of child abuse or neglect” [637(a)(6)(A)]

4. What this means-1 -Not ALL children under age 3 with substantiated cases receive an evaluation. -Screening can be used to determine whether an evaluation is needed. -Spirit of the law: These children will receive special attention to determine whether an early intervention referral is needed. Whether children are screened or all children are referred is left up to the discretion of the state. It is up to the State to determine how children referenced in section 106(b)(2)(A)(xxi) of CAPTA will be screened and, if appropriate, referred to the Part C early intervention program in the State. See Keller-Allen (2007) inForum Brief Policy Analysis www.projectforum.org and Child Welfare Policy Manual www.acf.hhs.gov/j2ee/programs/cb/laws_policy/laws/cwpm/index.jsp Whether children are screened or all children are referred is left up to the discretion of the state. It is up to the State to determine how children referenced in section 106(b)(2)(A)(xxi) of CAPTA will be screened and, if appropriate, referred to the Part C early intervention program in the State. See Keller-Allen (2007) inForum Brief Policy Analysis www.projectforum.org and Child Welfare Policy Manual www.acf.hhs.gov/j2ee/programs/cb/laws_policy/laws/cwpm/index.jsp

5. What this means-2 -Referral can come from child welfare (CW) OR CW can use other referral sources (e.g., physicians) to screen and refer -No requirement to refer siblings under age 3 who are not the subject of abuse or neglect, but encouraged to refer siblings who may have delays. The IDEA regulations at 45 CFR 303.321(d) provide procedures for use by primary referral sources for referring a child to a Part C agency for evaluation and assessment or appropriate services. Under 45 CFR 303.321(d)(3) primary referral sources include hospitals, physicians and social service agencies, which can include the Child Protective Services (CPS) agency, as well as other sources. Some State CPS agencies are using other primary referral sources to assist in screening a child (after substantiation), while other State IDEA Part C programs are working with CPS agencies and training CPS social workers to conduct appropriate screenings. Both approaches meet the CAPTA requirements. There may be Federal confidentiality restrictions for the State to consider when implementing this CAPTA provision. The State is not required to refer other children in the household under the CAPTA provision. However, we encourage States to refer all children who are suspected of having a disability and warrant a referral to early intervention services, taking into consideration Federal confidentiality restrictions when implementing this CAPTA provision. From: Child Welfare Policy Manual www.acf.hhs.gov/j2ee/programs/cb/laws_policy/laws/cwpm/index.jsp The IDEA regulations at 45 CFR 303.321(d) provide procedures for use by primary referral sources for referring a child to a Part C agency for evaluation and assessment or appropriate services. Under 45 CFR 303.321(d)(3) primary referral sources include hospitals, physicians and social service agencies, which can include the Child Protective Services (CPS) agency, as well as other sources. Some State CPS agencies are using other primary referral sources to assist in screening a child (after substantiation), while other State IDEA Part C programs are working with CPS agencies and training CPS social workers to conduct appropriate screenings. Both approaches meet the CAPTA requirements. There may be Federal confidentiality restrictions for the State to consider when implementing this CAPTA provision. The State is not required to refer other children in the household under the CAPTA provision. However, we encourage States to refer all children who are suspected of having a disability and warrant a referral to early intervention services, taking into consideration Federal confidentiality restrictions when implementing this CAPTA provision. From: Child Welfare Policy Manual www.acf.hhs.gov/j2ee/programs/cb/laws_policy/laws/cwpm/index.jsp

6. Why implement links between child welfare and Part C? Highest rates of abuse and neglect occur in infants and toddlers 16.1 per 1000 children under age 3 High rates of developmental delay in this population 23-61% of children known to CW have delays in development, communication, behavior 10-12% of children in general population have developmental dleays. 10-12% of children in general population have developmental dleays.

7. Underuse of EI in CW Rosenberg et al, 2004 17% of children in CW eligible for Part C were receiving services Stahmer et al., 2005 40% of children under 3 exhibited serious developmental or behavioral risk Only 13% of these children received any early intervention services In the Stahmer et al., 2005 study, we used a very conservative measure of risk—that is, In general, serious risk was considered present when a child performed at least 2 standard deviations (SDs) below the mean on a specific measure (cognitive, behavioral, communication, adaptive). This amount of difference from the norm qualifies children for early intervention services in the majority of states in the United States (83%) and warrants a referral for additional evaluation in all states. These were primarily screening assessments used in this study. You can see the very high rate of risk, with low rates of service use. These data were collected in 1999-2000 The number of children with high need was the same for children who were in foster care and those who remained in the home after investigation. These are just two examples of recent studies examining the high rate of risk in this population and the clear underuse of services by this population In the Stahmer et al., 2005 study, we used a very conservative measure of risk—that is, In general, serious risk was considered present when a child performed at least 2 standard deviations (SDs) below the mean on a specific measure (cognitive, behavioral, communication, adaptive). This amount of difference from the norm qualifies children for early intervention services in the majority of states in the United States (83%) and warrants a referral for additional evaluation in all states. These were primarily screening assessments used in this study. You can see the very high rate of risk, with low rates of service use. These data were collected in 1999-2000 The number of children with high need was the same for children who were in foster care and those who remained in the home after investigation. These are just two examples of recent studies examining the high rate of risk in this population and the clear underuse of services by this population

8. Possible Impact on Part C As much as: 70% increase in referrals to Part C 167,000 infants and toddlers 20% increase in Part C enrollment 44,000 infants and toddlers Rosenberg & Rosenberg, 2004

9. Challenges for Part C Increasing capacity Coordination of screening and evaluations Multiple placements Infant mental health issues Complex needs of biological families Multiple caregivers--consent Part C as a voluntary service

10. Current Research Project Referral methods from CW to Part C Screening and evaluation procedures Service delivery modifications needed for this population Methods of tracking and referral This particular project examines the response to CAPTA regulations from the perspective of Part C coordinators. We only collected information from Part C coordinators at the state level. Therefore, we don’t have clear information regarding collaboration or the extent because we do not have the child welfare perspective. However, we felt this was one place to begin. Additionally, these are global state level data, and in many states services, collaboration and practices may vary at a more local level. However, we can see a general picture of what is happening in the states from these data.This particular project examines the response to CAPTA regulations from the perspective of Part C coordinators. We only collected information from Part C coordinators at the state level. Therefore, we don’t have clear information regarding collaboration or the extent because we do not have the child welfare perspective. However, we felt this was one place to begin. Additionally, these are global state level data, and in many states services, collaboration and practices may vary at a more local level. However, we can see a general picture of what is happening in the states from these data.

11. Measure 23 questions in the 4 areas of interest Yes/no, multiple choice or short answer No child specific information State level data Survey is available on the website for the call Survey of states’ Part C Agency’s CAPTA-specific policies and practices Referral Receipt and Response How does your agency receive referrals from child welfare? 2. How does your Part C agency follow-up if a family does not show up for a scheduled appointment? 3. Are siblings of children with a substantiated case of abuse or neglect referred to Part C? 4. What action is taken if a biological parent refuses to give consent for determining eligibility for Part C services? 5. For children in foster care, can their foster care providers give consent?6. What action is taken if the foster care provider refuses to give consent for the evaluation? Screening and Assessment 7. Do you have procedures in place that include the administration of a screening by your agency or any other agency for infants and toddlers who are referred to Part C? 8. Does this screening apply to all children evaluated by Part C or is it specific to children referred by child welfare? 9. Who performs this initial screening for children referred through child welfare? 10. Do children in child welfare receive periodic developmental screening regardless of symptoms? 11. Are all children referred by child welfare eligible for Part C services irrespective of screening/evaluation results? 12. Does your Part C agency have any written policies that social emotional assessment tools be included as part of the evaluation (screening or assessment) process? 13. Does Part C have any written policies regarding the collection of collateral developmental information from child welfare? Service Delivery 14. Must the identified child have a permanent residence before intervention begins? 14a. If no, how does a child’s change of residence to a new county effect the service delivery process? 15. If children are in out-of-home care are biological parents included in the IFSP? 16. Do families of children referred by child welfare typically receive parent training as a component of Part C IFSPs? 17. Who is eligible to receive parent training? 18. Do Part C direct service providers receive any special training in working with children and families referred through child welfare? Methods of Tracking 19. Does your Part C agency (or contracted providers) collaborate with child welfare in the development of the IFSP or delivery of service? Please list the means of collaboration. 20. Does your Part C agency have a method of tracking how many children are referred to Part C by child welfare? 21. Does your Part C agency have a method of tracking how many children are referred to Part C by child welfare receive an initial evaluation for Part C eligibility? 22. Does your Part C agency have a method of tracking whether or not children referred by child welfare and evaluated by Part C are eligible for services? 23. Does your Part C agency have a method of tracking whether or not children referred by child welfare receive Part C services?Survey of states’ Part C Agency’s CAPTA-specific policies and practices Referral Receipt and Response How does your agency receive referrals from child welfare? 2. How does your Part C agency follow-up if a family does not show up for a scheduled appointment? 3. Are siblings of children with a substantiated case of abuse or neglect referred to Part C? 4. What action is taken if a biological parent refuses to give consent for determining eligibility for Part C services? 5. For children in foster care, can their foster care providers give consent?6. What action is taken if the foster care provider refuses to give consent for the evaluation? Screening and Assessment 7. Do you have procedures in place that include the administration of a screening by your agency or any other agency for infants and toddlers who are referred to Part C? 8. Does this screening apply to all children evaluated by Part C or is it specific to children referred by child welfare? 9. Who performs this initial screening for children referred through child welfare? 10. Do children in child welfare receive periodic developmental screening regardless of symptoms? 11. Are all children referred by child welfare eligible for Part C services irrespective of screening/evaluation results? 12. Does your Part C agency have any written policies that social emotional assessment tools be included as part of the evaluation (screening or assessment) process? 13. Does Part C have any written policies regarding the collection of collateral developmental information from child welfare? Service Delivery 14. Must the identified child have a permanent residence before intervention begins? 14a. If no, how does a child’s change of residence to a new county effect the service delivery process? 15. If children are in out-of-home care are biological parents included in the IFSP? 16. Do families of children referred by child welfare typically receive parent training as a component of Part C IFSPs? 17. Who is eligible to receive parent training? 18. Do Part C direct service providers receive any special training in working with children and families referred through child welfare? Methods of Tracking 19. Does your Part C agency (or contracted providers) collaborate with child welfare in the development of the IFSP or delivery of service? Please list the means of collaboration. 20. Does your Part C agency have a method of tracking how many children are referred to Part C by child welfare? 21. Does your Part C agency have a method of tracking how many children are referred to Part C by child welfare receive an initial evaluation for Part C eligibility? 22. Does your Part C agency have a method of tracking whether or not children referred by child welfare and evaluated by Part C are eligible for services? 23. Does your Part C agency have a method of tracking whether or not children referred by child welfare receive Part C services?

12. Participants 43 (84%) states (of 51) responded 37 via email 2 via fax 4 via telephone Part C Coordinators (69%) or their representatives 20% Part C administrative staff (manager, supervisor, director) 10% consultant or program specialist

13. Referral Receipt and Response 71% reported multiple referral methods Other=These included the use of the internet (3 states), an interagency liaison (1 state), a weekly email from child welfare to Part C listing all new substantiated cases of abuse and neglect in children under age 3 (1 state), referrals from other providers (1 state), and the use of an automated data management system common to both agencies. Other=These included the use of the internet (3 states), an interagency liaison (1 state), a weekly email from child welfare to Part C listing all new substantiated cases of abuse and neglect in children under age 3 (1 state), referrals from other providers (1 state), and the use of an automated data management system common to both agencies.

14. Referral Receipt and Response Most frequently used method Other=through the internet, weekly meetings with child welfare or community providers (12%). Several states (24%) utilize, or are in the process of developing, a document specifically designed for CAPTA referrals. Other=through the internet, weekly meetings with child welfare or community providers (12%). Several states (24%) utilize, or are in the process of developing, a document specifically designed for CAPTA referrals.

15. Sibling Referrals Wide variability 38% referred all siblings under age 3 as “involved” in the case 40% only referred if developmental concerns in the sibling 21% did not routinely refer siblings

16. If parent refuse to consent

17. Foster Parent Consent Of interest, none of the respondents referred to their right under IDEA to pursue an evaluation even after parent’s refusal to consent through the use of mediation or due process procedures (see 34 C.F.R. §300.504 (b)). Of interest, none of the respondents referred to their right under IDEA to pursue an evaluation even after parent’s refusal to consent through the use of mediation or due process procedures (see 34 C.F.R. §300.504 (b)).

18. Screening & Assessment 71% of states implemented screening 27% specific protocol for CAPTA referrals 1 state screened all children except CAPTA referrals 2 states in the process of developing screening policy for CAPTA referrals 73% screen regardless of referral source73% screen regardless of referral source

19. Who conducts screening? For the seven states reporting that screenings may be conducted by other sources, three accepted screenings conducted by local physicians, three accepted screenings from school districts, and one state used a joint liaison between child welfare and Part C to conduct screenings. Seventy percent of states had only one screening source. Of those, Part C personnel conducted screenings for children referred by child welfare in 48% of the states, followed by contracted agencies (24%), child welfare (14%) and other sources (14%). Twenty-one percent of respondents indicated that Part C offered periodic screening of children referred through child welfare. Only three states (7%) provided services to children referred under CAPTA regardless of assessment outcome. All other states (93%) required that children in child welfare meet the same eligibility criteria as other children referred for Part C services in their state.For the seven states reporting that screenings may be conducted by other sources, three accepted screenings conducted by local physicians, three accepted screenings from school districts, and one state used a joint liaison between child welfare and Part C to conduct screenings. Seventy percent of states had only one screening source. Of those, Part C personnel conducted screenings for children referred by child welfare in 48% of the states, followed by contracted agencies (24%), child welfare (14%) and other sources (14%). Twenty-one percent of respondents indicated that Part C offered periodic screening of children referred through child welfare. Only three states (7%) provided services to children referred under CAPTA regardless of assessment outcome. All other states (93%) required that children in child welfare meet the same eligibility criteria as other children referred for Part C services in their state.

20. Social/Emotional Assessment Tool 71% specified use of S/E tool 28% of these had a specific tool ASQ-SE (7 states) TABS (1 state) DECA (1 state) Others had S/E component of developmental assessment or left choice up to clinician 29% did not have guidelines for S/E assessment Stages Questionnaire-Social Emotional (ASQ-SE; Squires, Bricker, & Twombly, 2002), one state used the Temperament and Atypical Behavior Scale (TABS; Bagnato, Neisworth, Slavia & Hunt, 1999) and one state used the Devereux Early Childhood Assessment (DECA; LeBuffe & Naglieri, 2003). Stages Questionnaire-Social Emotional (ASQ-SE; Squires, Bricker, & Twombly, 2002), one state used the Temperament and Atypical Behavior Scale (TABS; Bagnato, Neisworth, Slavia & Hunt, 1999) and one state used the Devereux Early Childhood Assessment (DECA; LeBuffe & Naglieri, 2003).

21. Collection of Info from CW 29% had policies requiring collection of developmental info from CW as part of evaluation process 8 states had general polices that included CW 4 states had policies specific to CW 3 states referred to need to obtain parental permission to obtain collateral info At least 2 states automatically received collateral info as part of the referral process Including one state that had a “Family Strengths and Needs Assessment” that was included with the referral from child welfare (incl. in 4 with specific policies)Including one state that had a “Family Strengths and Needs Assessment” that was included with the referral from child welfare (incl. in 4 with specific policies)

22. Service Delivery 95% of states did not require permanent residence before IFSP or services began IFSP transfers across counties / areas Service interruption if Part C not informed of change in residence 95% of states attempted to include biological parents in the IFSP process Dependent on CW directive; locating parents; parent desire to participate No inclusion if parental rights terminated

23. Parent Training / Education Thirty-three percent of states always included parent training as a component of the IFSP, and 43% sometimes include parent training, dependent on family need. Four states indicated that parent training was embedded into all Part C services. Of those states that either sometimes or always offered parent training, 100% made this training available to foster parents. Training offered to biological parents varied by circumstances: 38% always offered training to the biological parent, regardless of the circumstances; 43% only offered training to biological parents if the child resided in the home, 30% also offered training to the biological parent if the child was in out-of-home care but reunification remained a goal. Thirty-three percent of states always included parent training as a component of the IFSP, and 43% sometimes include parent training, dependent on family need. Four states indicated that parent training was embedded into all Part C services. Of those states that either sometimes or always offered parent training, 100% made this training available to foster parents. Training offered to biological parents varied by circumstances: 38% always offered training to the biological parent, regardless of the circumstances; 43% only offered training to biological parents if the child resided in the home, 30% also offered training to the biological parent if the child was in out-of-home care but reunification remained a goal.

24. Training for Part C Providers 19% offered training in how to work with families referred through CW 12% in the process of developing training Training focused primarily on administrative issues rather than clinical One state had liaison position to coordinate services 3 states mentioned trainings in interventions specific to this population States also reported a focus on building/enhancing child welfare-Part C relationships through local, regional, and statewide trainings, as well as through more informal means such as brown bags and phone conversations. Half of states (52%) offered no training in serving children and families in child welfare populations. States also reported a focus on building/enhancing child welfare-Part C relationships through local, regional, and statewide trainings, as well as through more informal means such as brown bags and phone conversations. Half of states (52%) offered no training in serving children and families in child welfare populations.

25. Collaboration Between Agencies 84% report collaboration efforts for IFSP development and/or service delivery Forms of collaboration Consultation regarding assessments/services Joint evaluations/staffing Sharing of information Combined home visits Inclusion of CW in IFSP Inclusion in IFSP most common 79% While a few states reported that collaboration was usual practice, others noted that it could be sporadic, informal, and limited by the large caseloads typically held by welfare workers.Inclusion in IFSP most common 79% While a few states reported that collaboration was usual practice, others noted that it could be sporadic, informal, and limited by the large caseloads typically held by welfare workers.

26. Methods of Tracking

27. Recommendations Referral Process Screening and Assessment Service Delivery Tracking

28. Referral Process Standardized referral forms Voluntary vs. mandated service provision System for sibling referral Legal issues around consent First, given that written contact is the most widely used referral strategy reported by respondents (80%), representatives from child welfare and Part C need to collaboratively design and implement standardized CAPTA referral forms. Collaborative development of a specialized CAPTA referral document that includes demographics, medical and developmental concerns, caregiver and biological parent contact information. Duplicate forms for both agencies to facilitate follow-up. Differences in agency culture regarding mandating services. Unique challenges in this population that my affect willing ness to participate. No state mentioned Part C right to challenge consent or the ‘reasonable efforts’ to ensure parent aware of the services available. Legal consultation should include a determination of when and how to challenge a parents’ decision to decline services. Explore the possibility of coordinated methods of obtaining consent. A system for referral of siblings under age 3 is essential given increased risk of developmental issues. State require legal consultation regarding parental (foster and biological) to consent or decline services and a system in place to report refusals to child welfare.First, given that written contact is the most widely used referral strategy reported by respondents (80%), representatives from child welfare and Part C need to collaboratively design and implement standardized CAPTA referral forms. Collaborative development of a specialized CAPTA referral document that includes demographics, medical and developmental concerns, caregiver and biological parent contact information. Duplicate forms for both agencies to facilitate follow-up. Differences in agency culture regarding mandating services. Unique challenges in this population that my affect willing ness to participate. No state mentioned Part C right to challenge consent or the ‘reasonable efforts’ to ensure parent aware of the services available. Legal consultation should include a determination of when and how to challenge a parents’ decision to decline services. Explore the possibility of coordinated methods of obtaining consent. A system for referral of siblings under age 3 is essential given increased risk of developmental issues. State require legal consultation regarding parental (foster and biological) to consent or decline services and a system in place to report refusals to child welfare.

29. Screening and Assessment Legality of screening in Part C Possible duplication of screening services Guidelines for appropriate assessment of social/emotional issues Difficulty sharing information Several states that did not screen mentioned the issue that Part C must evaluate. Legal consultation regarding the use of screenings is necessary with consideration for the large number of children that may be referred from child welfare under CAPTA and who should conduct screening. Part C and child welfare should work together to examine intake and periodic screening and assessment policies to ensure that services are not being duplicated and that information on developmental status is shared between agencies. CW also conducts intake and period screening in many states, yet Part C is conducting a majority of screenings for CAPTA kids. Is this overlap? Consistent assessment of children referred through child welfare for social/emotional and attachment difficulties is imperative. Valid and reliable tools for this population should be identified and assessment providers should be specifically trained to use these assessments for children in child welfare. Difficult due to possible lack of familiarity of caregiver with child or caregivers own issues. Need guidelines to deal with these issues Part C and child welfare should work together to develop policies for collection of collateral information as part of the comprehensive evaluation. Legal consultation regarding interagency release of child and family specific information is necessary. Information that can be disclosed without consent should be shared at the time of referral. Systematic method of informing Part C as early as possible about placement changes will reduce breaks in servicesSeveral states that did not screen mentioned the issue that Part C must evaluate. Legal consultation regarding the use of screenings is necessary with consideration for the large number of children that may be referred from child welfare under CAPTA and who should conduct screening. Part C and child welfare should work together to examine intake and periodic screening and assessment policies to ensure that services are not being duplicated and that information on developmental status is shared between agencies. CW also conducts intake and period screening in many states, yet Part C is conducting a majority of screenings for CAPTA kids. Is this overlap? Consistent assessment of children referred through child welfare for social/emotional and attachment difficulties is imperative. Valid and reliable tools for this population should be identified and assessment providers should be specifically trained to use these assessments for children in child welfare. Difficult due to possible lack of familiarity of caregiver with child or caregivers own issues. Need guidelines to deal with these issues Part C and child welfare should work together to develop policies for collection of collateral information as part of the comprehensive evaluation. Legal consultation regarding interagency release of child and family specific information is necessary. Information that can be disclosed without consent should be shared at the time of referral. Systematic method of informing Part C as early as possible about placement changes will reduce breaks in services

30. Service Delivery Training in working with children in CW Infant mental health training Care-giving skills of parents in this population Parent Training Collaborative Care Training in interventions specifically designed for children in child welfare should be provided to Part C providers. Training in early childhood mental health strategies, cross cultural sensitivity and working with at-risk families must be provided Research focusing on appropriate and effective early intervention methods for children who are victims of abuse and neglect who also have early intervention needs is needed along with the development of practice guidelines for early intervention providers. Parent education and training in facilitation of development and parenting practices should be provided to both biological and foster parents. Efforts to include biological parents in intervention are needed. Helpful to reduce multiple placements and to increase caregiver competence. Coordination of parent education and training between agencies is essential to reduce duplication of service and to share expertise. Child welfare and Part C should build collaborative partnerships in treatment planning, development and delivery to ensure a systematic continuum of services for children served by both systems. Both agencies should participate in IFSP development; Better methods needed as currently system seems fragmented Training in interventions specifically designed for children in child welfare should be provided to Part C providers. Training in early childhood mental health strategies, cross cultural sensitivity and working with at-risk families must be provided Research focusing on appropriate and effective early intervention methods for children who are victims of abuse and neglect who also have early intervention needs is needed along with the development of practice guidelines for early intervention providers. Parent education and training in facilitation of development and parenting practices should be provided to both biological and foster parents. Efforts to include biological parents in intervention are needed. Helpful to reduce multiple placements and to increase caregiver competence. Coordination of parent education and training between agencies is essential to reduce duplication of service and to share expertise. Child welfare and Part C should build collaborative partnerships in treatment planning, development and delivery to ensure a systematic continuum of services for children served by both systems. Both agencies should participate in IFSP development; Better methods needed as currently system seems fragmented

31. Tracking Development of consistent tracking methods in all areas Coordination with AFCARS and Part C data collection systems already in place Consistent tracking will help determine if too many or too few children are being referred and allow for capacity building to address the needs of an increased nunber of children. Consistent tracking will help determine if too many or too few children are being referred and allow for capacity building to address the needs of an increased nunber of children.

32. Funding Advocacy is needed for funding the CAPTA regulations in order to make the appropriate changes