BILL ANALYSIS                                                                                                                                                                                                    �




                                                                  AB 1766
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          Date of Hearing:   April 29, 2014

                        ASSEMBLY COMMITTEE ON HUMAN SERVICES
                                  Mark Stone, Chair
                   AB 1766 (Nazarian) - As Amended:  April 23, 2014
           
          SUBJECT  :  Foster youth: transitional housing pilot project

           SUMMARY  :  Provides Los Angeles County the authority to establish  
          a transitional housing pilot project in conjunction with the  
          University of California, Los Angeles (UCLA) and First Star,  
          Incorporated (FSI).  Specifically,  this bill  :   

          1)Makes Legislative findings and declarations about the  
            educational challenges facing children in foster care and that  
            expanding the First Star UCLA Bruin Guardian Scholar Summer  
            Academy into a year-round placement would allow foster youth  
            to fully realize the benefits of going to college. 

          2)Requires the Department of Social Services, at the option of  
            the County of Los Angeles, to implement a pilot project in Los  
            Angeles County with UCLA and FSI, or a related nonprofit child  
            advocacy organization, to establish the "University-Affiliated  
            First Star High School Academy" (Academy). 

          3)Requires the Academy to be licensed as a transitional housing  
            placement provider (THPP) and  include the following  
            components:

             a)   Serve foster children who are attending high school and  
               are at least 13 years of age, but not older than 21 years  
               of age;

             b)   Provide housing units that are adequate, safe and  
               sanitary and meet existing requirements of the types of  
               living environments approved for a THPP, as specified, and  
               expands the types of living environments in which a foster  
               child may live to include, but not be limited to,  
               residential facilities for participants and supervisory  
               adults, dormitory, multioccupant, clustered, hub, and other  
               housing layouts and arrangements as are commonly found in a  
               college or university environment; and

             c)   Provide a program staffing ratio of one staff member for  
               every three residents: 









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          4)Requires the academy to be reimbursed at 160% of the monthly  
            THPP rate, as specified.

          5)Requires DSS to submit a report evaluating the effectiveness  
            of the pilot project to the appropriate committees of the  
            Legislature by January 1, 2020.

          6)Sunsets the pilot on January 1, 2024.

          7)Specifies that no child welfare services (CWS) realignment  
            funds may be appropriated for the purposes of the pilot.   

           EXISTING LAW   
          1)States that the purpose of foster care law is to provide  
            maximum safety and protection for children who are currently  
            being physically, sexually, emotionally abused, neglected, or  
            exploited, and to ensure the safety, protection, and physical  
            and emotional well-being of children who are at risk of harm.   
            (W&I Code 300.2)

          2)States the intent of the Legislature to preserve and  
            strengthen a child's family ties whenever possible and to  
            reunify a foster youth with his or her biological family  
            whenever possible, or to provide a permanent placement  
            alternative, such as adoption or guardianship.  (W&I Code  
            16000)

          3)Reaffirms the Legislature's commitment to children who are in  
            out-of-home placement to live in the least restrictive, most  
            family like setting and to live as close to the child's family  
            as possible, as specified, and to provide family reunification  
            services in order to facilitate the expeditious reunification  
            of the child with his or her family.  (W&I Code 16000)

          4)Requires the juvenile court to place a child in foster care  
            into a placement that is the least restrictive or most family  
            like and the most appropriate setting that is available and in  
            close proximity to the parent's home, proximity to the child's  
            school, and consistent with the selection of the environment  
            best suited to meet the child's special needs and best  
            interests.  (W&I Code 16501.1(c)(1))

          5)Requires placement of a child in foster care to be made in the  
            following priority:  placement with relatives, nonrelated  









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            extended family members, tribal members, and foster family  
            homes, certified homes of foster family agencies, intensive  
            treatment or multidimensional treatment foster care homes,  
            group care placements, and residential treatment facilities,  
            as specified.  (W&I Code 16501.1(c)(1))

          6)If a group care placement is selected for a child, requires  
            the case plan to indicate the needs of the child that  
            necessitate the placement, the plan for transitioning the  
            child to a less restrictive environment, and the projected  
            timeline by which the child will be transitioned to a less  
            restrictive environment; and for the case plan to be reviewed  
            by the juvenile court and updated at least semiannually by the  
            CWA.  (W&I Code 16501.1(c)(2))

          7)Limits the placement of children under the age of 12 into  
            group care upon specified conditions if the placement is for  
            less than six months and is needed to provide specialized or  
            intensive treatment for the child, as specified.  (W&I Code  
            361.2)

          8)States the intent of the Legislature that no child or youth in  
            foster care reside in group care for longer than one year and  
            requires DSS to provide updates to the Legislature regarding  
            the outcomes of assessments of children and youth who have  
            been in group homes for longer than one year and the  
            corresponding outcomes of transitions, or plans to transition,  
            them into family settings.  (W&I Code 16010.8)

          9)Requires the juvenile court, when considering placement of a  
            child in foster care, to make full consideration for the  
            proximity of the child's natural parents to the placement in  
            order to facilitate visitation and family reunification, and  
            if possible, for the placement to be made in the home of a  
            relative, unless as otherwise specified.  (Family Code  
            7950(a))

          10)Requires county child welfare agencies (CWA) to make diligent  
            efforts, as determined by the court, to locate an appropriate  
            relative before any child may be placed in long-term foster  
            care, and provides that nothing may preclude a search for an  
            appropriate relative while the child is in foster care.   
            (Family Code 7950(a(1) and (c))

          11)In fulfilling the Legislature's intent to ensure quality care  









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            for children who are placed in the continuum foster care  
            placement settings, requires DSS to establish, in consultation  
            with county welfare departments and other stakeholders, a  
            working group to develop recommended revisions to the current  
            delivery of services provided by foster family agencies and  
            group homes, as specified.  (W&I Code 11461.2)

          12)Requires the recommended revisions to consider, among other  
            things, how to ensure the provision of services in family-like  
            settings including after care services, when appropriate, and  
            to submit the revisions in a report to the Legislature by  
            October 1, 2014, as specified.  (W&I Code 11461.2(d))

          13)For children over the age of three who are placed into foster  
            care, permits the juvenile court to order family reunification  
            services, to be provided by a CWA, for a period of 12 months  
            after the child entered foster care with an extension of  
            six-months, as specified.  (W&I Codes 361.5(a)(1)(A) and  
            361.5(a)(3))

          14)Requires THPP providers, in order to be eligible to receive  
            federal and state foster care payments and to provide  
            transitional housing services to children in foster care  
            between 16 and 19 years of age to be certified by their  
            respective county prior to licensure by DSS, and to be  
            licensed by DSS.  (W&I Code 16522.1 and H&S Code 1559.110)

          FISCAL EFFECT  :  Unknown

           COMMENTS  :   

           Maintaining the Family  :  Historically, it has been the stated  
          policy of California that when a child is removed from the home,  
          first preference should be given to placing the child with  
          another parent, or with his or her relatives whenever possible  
          and appropriate.  This has helped to preserve and strengthen the  
          social bedrock of our society, by keeping families together and  
          reducing society's reliance on its social welfare system. 

           Child Welfare Services  :  The purpose of California's Child  
          Welfare Services (CWS) system is to provide for the protection  
          and the health and safety of children.  Within this purpose, the  
          desired outcome is to reunite children with their biological  
          parents, when appropriate, to help preserve and strengthen  
          families.  However, if reunification with the biological family  









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          is not appropriate, children are placed in the best environment  
          possible, whether that is with a relative, through adoption, or  
          with a guardian, such as a nonrelated extended family member, as  
          specified.  In the case of children who are at risk of abuse,  
          neglect or abandonment, county juvenile courts hold legal  
          jurisdiction and children are served by the CWS system through  
          the appointment of a social worker.  Through this system, there  
          are multiple stages where the custody of the child or his or her  
          placement are evaluated, reviewed and determined by the judicial  
          system, in consultation with the child's social worker to help  
          provide the best possible services to the child. 

          At the time a child is identified as needing child welfare  
          services and is in the temporary custody of a social worker, the  
          social worker is required to identify whether there is a  
          relative or guardian to whom a child may be released, unless the  
          social worker believes that the child would be at risk of abuse,  
          neglect or abandonment if placed with that relative or guardian.  
           The W&I Code also lays out the conditions under which a court  
          may deem a child a dependent or ward of the court, including  
          when the parent has been incarcerated or institutionalized and  
          is unable to arrange for care for the child, such as placement  
          with a known relative or nonrelative extended family member  
          (NREFM).  If the child is deemed a dependent or ward of the  
          court, the court may maintain the child in his or her home,  
          remove the child from the home but with the goal of reunifying  
          the child with his or her family, or identify another form of  
          permanent placement.  Unless the child is unable to be placed  
          with the parent, the court is required to give preference to a  
          relative of the child in order to preserve the child's  
          association with his or her family.  Associated with the  
          placement, the assigned social worker shall develop a case plan  
          for the child, which outlines the placement for the child, sets  
          forth services necessary for the child, and outlines the  
          provision of reunification services, if necessary and  
          appropriate.

           Reunification and permanency goals  :  It has long been the policy  
          of the state to place children who have been removed from the  
          "care, custody, and control" of their parent(s) in an  
          environment that is as least restrictive as possible and is in  
          close proximity to their family, if appropriate, in order to  
          facilitate the successful reunification of the child with his or  
          her family as quickly as possible.  The purpose is to limit as  
          best as possible the already traumatic experiences a child goes  









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          through with having to be removed from his or her home due to  
          abuse and neglect. 

          When children are removed from the home, but the court  
          determines, in consultation with a child's social worker, that  
          the child would ultimately benefit from being returned to the  
          family, the court can order reunification services for the child  
          and his or her family.  Reunification services are generally  
          developed on a case-by-case basis to accommodate and respond to  
          the needs of the child and the parents to better facilitate the  
          child's reunification with his or her parent(s). 

          Reunifications services can include family therapy, parenting  
          classes, drug and alcohol abuse treatment, respite care, parent  
          support groups, home visiting programs, and other coordinated  
          and tailored services necessary to assist the child and the  
          family with reunification.  Under current law, for children  
          under the age of three, reunification services are offered for  
          six months and 12 months for children over the age of three.  A  
          six-month extension may be made if the court finds there is  
          substantial probability that the child will be returned to the  
          physical custody of his or her parent(s) within the extended  
          time period or that reasonable services have not been provided  
          to the parent(s).

          In cases where family reunification is deemed unsuccessful or is  
          deemed not to be in the best interests of the child, placement  
          with a relative, a NREFM or a family foster home, in that order  
          of priority, is required for consideration.  Only in more  
          challenging situations are group homes or other intensive  
          treatment placement options considered in order to help  
          stabilize the needs of the child in order to transition him or  
          her into a less restrictive environment, such as a family-like  
          placement, e.g. a relative, NREFM or a foster caregiver.

           Transitional Housing Placement Program (THPP)  :  THPP is a type  
          of foster care placement for foster youth who are 16 and 17  
          years of age, but can serve 18 year olds, as well.  According to  
          DSS, the goal of the program is to provide a safe living  
          environment so that the youth can practice the skills necessary  
          to live on their own upon leaving the foster care support  
          system. Through the program, foster youth live independently, as  
          provided through a Transitional Independent Living Plan (TILP),  
          which is developed by the youth in conjunction with his or her  
          social worker, the court, and other specified individuals who  









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          are required to provide support and care for the youth.  Through  
          the TILP, the youth receives an array of supportive services to  
          achieve the goals laid out in the TILP.  These services are  
          intended to help the youth in attaining emancipation preparation  
          goals, which include but are not limited to education  
          attainment, financial management skills, and gainful employment.  


          THPP, however, is not without its challenges.  Although it is a  
          program designed specifically for 16 and 17 year old foster  
          youth, it is not widely used, very costly, and has raised  
          questions as to whether it is appropriate to allow a foster  
          youth to live independently prior to age 18.  Like many children  
          who live with their biological parents until and likely after  
          age 18, a concern has been raised that placing a foster youth  
          into a THPP results in the youth growing up outside of a family  
          environment, and can result in unintended developmental harm to  
          the youth.  It is also estimated that many foster youth placed  
          in THPPs are predominantly 18 years of age.

           Congregate care reform (CCR)  :  Over the past 25 years the  
          Legislature has taken numerous and continuous steps towards  
          decreasing the reliance on congregate care, otherwise referred  
          to as group home care for children in foster care.  Group homes  
          have been a consistent presence in the state's child welfare  
          services (CWS) system, however, their use has been on the  
          decline.  The decline in the use of group homes has been, in  
          large part, due to the growing amount of widely available  
          research that has demonstrated that placing maltreated children  
          in group homes should be used only on a short-term basis for  
          emergency or crisis treatment. In fact, the Legislature's  
          involvement in CCR has been extensive.  Over the past 20 years,  
          a number of legislative, budget, administrative, and advocacy  
          based efforts have been pursued to reform the state's CWS system  
          and reduce its reliance upon group homes:

               1)     SB 2236 (Presley) Chapter 2234, Statutes of 1990 -  
                 Established the intensive treatment foster care (IFTC)  
                 pilot program to transition emotionally disturbed  
                 children from group care to non-institutional family  
                 homes with intensive treatment and support services.

               2)     AB 636 (Bates) Chapter 673, Statutes of 1993 - Made  
                 permanent the ITFC program limited group home placements  
                 to short term, emergency placements for arranging  









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                 placement in in a less restrictive setting. 

               3)     AB 1187 (Bates) Chapter 1088, Statutes of 1993 -  
                 Limits the placement of children under six years of age  
                 in group care.

               4)     AB 2297 (Cunneen) Chapter 274, Statutes of 1996 -  
                 Established the wraparound services pilot program to  
                 provide intensive home-based services for children in  
                 foster care in order to avoid placement in institutional  
                 facilities, i.e. group homes.

               5)     SB 933 (Thompson) Chapter 311, Statutes of 1998 -  
                 Made significant changes to CWS law, including a  
                 requirement of DSS to re-examine the role of group care  
                 for children in foster care. The final SB 933 report  
                 proposed a system redesign with 31 recommendations and a  
                 five-year reform implementation plan.

               6)     In 2004 the California Alliance for Child and Family  
                 Services (CACFS) convenes a "Framework for a New System  
                 for Residentially-Based Services in California"  
                 workgroup.

               7)     SB 1570 (Alquist) of 2006 - Although held in the  
                 Senate Appropriations Committee, it would have required  
                 DSS to create a plan for transforming group care into a  
                 system of residentially based services (RBS).

               8)     AB 1453 (Soto) Chapter 466, Statutes of 2007 -  
                 Established the RBS pilot program to reconfigure the  
                 current statewide system of group homes into a system of  
                 residentially based services and authorizes counties to  
                 enter into agreements to transform individual group home  
                 programs.

               9)     AB 2129 (Bass) Chapter 594, Statutes of 2010 -  
                 Extended the RBS pilot program until January 1, 2015 and  
                 requires DSS to submit a plan for transition to RBS by  
                 2014. 

               10)    In 2010 DSS pursues the CCR Integration Project to  
                 map current reform efforts and creates a six-month to  
                 two-year implementation plan. 










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               11)    SB 1013 (Senate Budget and Fiscal Review) Chapter  
                 35, Statutes of 2012 - The CWS budget trailer bill, which  
                 realigned CWS to counties, establishes a moratorium on  
                 the licensing of new group homes, and requires DSS to  
                 convene a CCR workgroup to provide recommendations to the  
                 Legislature and the Governor on how to reform the use of  
                 group homes in California.  The CCR report is due to the  
                 Legislature in October 2014.

          Additionally, in June 2011 the Assembly Human Services Committee  
          and the Assembly Select Committee on Foster Care held a joint  
          informational hearing on CCR.  The purpose of the hearing was to  
          examine group homes as a foster care placement, the status of  
          various reform efforts across California, and how the State can  
          move the reform agenda forward in new ways.  In its background  
          paper, the committees stated that:

               While there may be a need for some form of congregate care  
               in the continuum of child welfare services, policymakers  
               and child advocates have appropriately questioned how  
               foster youth are faring in these placements; how to define  
               the appropriate role for group homes in that continuum; and  
               how to align policy and practice with federal and state  
               child welfare goals for safety, well-being, and permanency  
               for foster youth.<1>

          It has been estimated that a child in foster care will  
          experience, on average, five foster care placements before they  
          are placed into a group home.  This has resulted in some sectors  
          of the CWS system declaring these children as "difficult to  
          place." In so doing, it has caused some people to associate a  
          foster youth's high number of placements with the youth's  
          behavior as opposed to whether the system properly identified  
          and provided appropriate and effective supportive services to  
          the child.  This is contrary to how the Legislature has worked  
          with the Governor, the administration, counties and child  
          welfare advocates to help put in place a system that responds to  
          the needs of youth in foster care by focusing on family  
          reunification and permanency.  The current and past efforts to  
          reform the state's CWS system have focused on how to better  
          identify and address the needs of foster youth through less  
          ---------------------------
          <1> Assembly Human Services Committee and Assembly Select  
          Committee on Foster Care Oversight Background Paper. Congregate  
          Care Reform: The Future of Foster Youth in Group Homes. June 28,  
          2011. Page 1.








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          restrictive and more accommodating services and placements,  
          rather than responding with placing a child into higher  
          structured and more restrictive services and placements. 

           Mission Focused Solutions Budget Proposal  :  Mission Focused  
          Solutions, a foster care advocacy organization, has requested a  
          one-time allocation of $750,000 to establish a program to  
          improve permanency outcomes for youth in foster care with  
          ongoing support of $1.15 million each year thereafter.  This  
          proposal is emblematic of the continuing efforts to move away  
          from group care and place more focus on making reunification and  
          permanency the desired outcome for children in foster care. 

          Specifically, the funding would provide start-up capital for two  
                                     counties to create or expand specialized youth permanency  
          programs, requiring that the county track and reinvest savings  
          to sustain the programs long term, replicating a successful  
          model pioneered by Sacramento County.  The program would target  
          youth age 9 and older and in care for at least 18 months, with a  
          strong emphasis on placing them into relative care settings. 

           Need for this bill  :  Stating the need for the bill, the author  
          writes: 

               Research shows that youth who have left the foster care  
               system are significantly more likely to drop out of high  
               school.  [This bill] allows California an opportunity to  
               pilot a new model, Academy 365, whose goal is to increase  
               the number of foster youth that graduate from high school  
               and obtain a higher education degree.  The partnership  
               between First Star and UCLA will pilot Academy 365, which  
               will offer an immersive sense of high achievement, numerous  
               undergraduate role models, stability and a robust ladder to  
               a successful future. It is necessary to prepare foster  
               youth in high school, like every other child, to aspire to  
               attend and thrive in college.  This is the goal [this bill]  
               seeks to accomplish.  

          Writing in support of the bill, the sponsor states:

               First Star supports [this bill] because we believe this  
               transformative pilot model is a major future pathway to  
               college for California's foster youth, of whom only 3% ever  
               achieve a Bachelor's degree.  Our stable and supportive  
               environment adjacent to UCLA, one of the nation's best  









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               universities, will create the support and motivation needed  
               for these youth to succeed in college and life afterwards.  
               In addition, we strongly believe the Academy will enhance  
               the possibilities of reunification or permanent adoption  
               for our students, because they will visibly improve  
               academically, behaviorally and in the caliber of their  
               hopes and dreams. 

               Our existing summer program at UCLA shows that this idea  
               works.  If in parallel and interactively, we extend the  
               model to year-round, we believe the results will be  
               incrementally beneficial.  The most elite families in the  
               nation send their youth to the high-achieving Choate,  
               Exeter and Andover residential academies? shouldn't we  
               pilot doing the same for the foster youth in our care?

          Writing in opposition to the bill, the Youth Law Center states:

               [This bill] asks the Legislature to create a special  
               congregate care program at almost twice the rate of  
               existing programs without any evidence that the model will  
               result in better outcomes for foster youth, and in spite of  
               evidence that the model actually harms youth.  The bill  
               preamble cites several statistics detailing the grim  
               outcomes foster youth face after leaving care: early  
               parenthood, homelessness, incarceration, and lack of a  
               college degree.  Yet there is no evidence to support that  
               an educational themed congregate care facility will result  
               in foster youth avoiding the cited perils.  A congregate  
               care facility where children live year round and have no  
               home to return to is an entirely different model from the  
               summer enrichment "camp-like" model that currently serving  
               youth and families well.

               Not only does the proposal fail to provide any evidence of  
               effectiveness, the bill effectively abandons permanency,  
               the key element that research has proven to provide a  
               protective factor for foster youth.  Children as young as  
               14 would be "permanently planned" to live out their foster  
               care days in congregate care.  Foster youth would be  
               "immersed" in a program that would deprive them of  
               opportunities to interact with people outside of the foster  
               care system in a normalized setting.  Foster youth in the  
               pilot program would effectively have a permanent plan of  
               "independent living" without the opportunity to maintain or  









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               cultivate a lifelong connection to a committed and caring  
               adult.  [This bill] also fails to detail how the well-being  
               of foster youth will be improved by placement in a  
               congregate care setting.

               [This bill] also back doors the moratorium and the CCR  
               process to avoid review and accountability of the proposed  
               program.  All other prospective congregate care providers  
               in the state face scrutiny of their proposed program to  
               insure that the program meets a current need and is  
               consistent with the state's policy of prioritizing foster  
               youth's need for permanency, safety and well-being.  The  
               proposed pilot, as described, is not aligned with the  
               objectives of CCR or the moratorium. Resources would be  
               much better utilized developing a high quality school that  
               all children in foster care can attend and investing in the  
               capacity of the child welfare agency to develop more family  
               settings for our most vulnerable youth.

           Staff comments  :  This bill aims to create a modified THPP as a  
          pilot program to be operated in collaboration with the County of  
          Los Angeles, Los Angeles Unified School District (LAUSD), and  
          the University of California, Los Angeles (UCLA) for the  
          purposes of establishing a University-Affiliated High School  
          Academy for foster youth.  The purpose is to build off of the  
          sponsor's experience in running a summer foster youth academy on  
          the campus of UCLA.  This summer program; the UCLA Bruin  
          Guardian Academy (BGA), is a one-month summer program, operated  
          by First Star, Incorporated,  whereby foster youth in Los  
          Angeles County live on the campus and are immersed in a "summer  
          bridge" type program.  Such programs often target  
          underrepresented and at-risk youth by exposing them to a college  
          campus environment to help raise awareness and build confidence  
          that they can go to and succeed in college.

          Though well intended, the bill raises a number of issues.  Most  
          predominantly is that as currently written it creates a pilot  
          program that is narrowly tailored in a manner that would make it  
          difficult for a more experienced or qualified entity other than  
          the sponsor to be awarded the pilot.  As a result, the bill  
          could be considered a "sole-sourced" bill.

          This measure also sets a statutory precedent that could  
          undermine the current moratorium on the approval of new group  
          homes.  As previously noted, for more than 25 years the state  









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          and foster care advocates have been working to reduce reliance  
          on group care as a placement for children in foster care.  By  
          establishing this pilot program, although aiming to modify THPP  
          to fit its model, the intent of the bill, according to the  
          sponsor, is to create a group care program for high school aged  
          youth.  If adopted, it would be equivalent to an exemption to  
          the current group home moratorium, which would likely result in  
          subsequent legislative efforts by current or prospective  
          entities to create their own exemption to operate a group home.   
          It would also further conflict with the current intent of the  
          Legislature that foster youth are not placed in a group care  
          setting for more than one year.  As proposed, this bill will  
          allow a foster youth to be in a group home for four consecutive  
          years.  This also contrary to one of the foundational purposes  
          of foster care; that it be as short-term and as temporary as  
          possible to reduce any undue harm due to the removal of the  
          child from the family, as well as avoid emotional and  
          developmental harm to the child due to separation from his or  
          her parent(s).

          The sponsor has also stated that this program would be intended  
          for foster youth who have no chance of being adopted or reaching  
          permanency.  However, this reasoning is problematic and contrary  
          to the purpose of the state's CWS system.  As children grow  
          older in foster care their chances of being adopted does  
          decrease, however, that opportunity never disappears.  Every  
          child in foster care has an opportunity to reach permanency  
          through reunification with his or her family, adoption, or  
          kinship guardianship. 

          Regarding the residential component, the pilot program allows  
          two sequential cohorts of 25 to 50 foster youth into the program  
          who would live together in the THPP until their graduation from  
          high school.  The intent would be for the youth to live in a  
          converted sorority house and attend high school at University  
          Senior High School, which also houses the Indian Springs  
          Continuation High School; an alternative high school.  However,  
          the bill does not provide a process for how school enrollment  
          would be addressed, nor whether it would comply with the  
          requirement that a placement be in the least restrictive  
          environment possible. 

          The sponsor also argues that by placing the youth in this  
          program, and in coordination and collaboration with UCLA, that  
          the program will "offer stability, an immersive sense of high  









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          achievement, numerous undergraduate role models and a robust  
          ladder to a successful future." Yet, if successful, this would  
          mean that the group care facility would be in close proximity to  
          UCLA's fraternity and sorority row.  Since many children in  
          foster care are removed from the home due to the substance abuse  
          of their parent(s), this raises concerns as to whether it is  
          appropriate to place foster youth in a group care facility that  
          is close to a hyper-social college environment; one where access  
          to alcohol and controlled substances are far greater than if  
          placed in a more neutrally located facility.  Foster youth are  
          already at-risk; it does not seem feasible to put them at  
          greater risk due to the surrounding environment of the facility.  


          According to the author, the purpose of focusing on modifying  
          the THPP program was to avoid pursuing an exemption to the  
          current moratorium on the licensing of new group homes, which  
          was established by the 2012 child welfare budget trailer bill.   
          This is problematic for several reasons.  First, the proposal  
          seeks to build upon a program that currently presents a number  
          of questions as to whether the THPP is appropriate for the model  
          they are seeking to operate. The THPP model is intended for  
          independent living, however, as proposed the pilot would operate  
          more like a group home with a structured and intensive  
          residential program.  Secondly, as currently written the bill  
          proposes to allow foster youth aged 14 through 21 to co-mingle  
          in the program.  This is contrary to current statutory  
          allowances, which prescribe that minor dependents and nonminor  
          dependents, those who are between the ages of 18 and 21, should  
          not live together in a group care setting.  Lastly, by focusing  
          on THPP as a means to implement the pilot, the bill bypasses  
          many group home requirements that have been established to  
          ensure the health and safety of its residents.  The modified  
          THPP in this bill, because of its independent structure, would  
          lack many of those group home protections.

          Additionally, as indicated in the bill, the pilot program would  
          be described as an "academy," however, it would not be academic  
          in nature nor does it establish a boarding school structure.  An  
          academy is generally considered to be a secondary or  
          post-secondary school that provides special instruction.  As  
          proposed, the bill establishes a group care program, not an  
          academy. Further, the bill as currently written lacks  
          substantial detail regarding what types of services are provided  
          to the youth in the program.  Because it seeks to operate a  









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          group care model within a modified THPP, it does not have to  
          comply with existing state group home laws and regulations;  
          rather it establishes a completely new out-of-home group care  
          model under THPP.  This is concerning because it would only be  
          required to comply with the less stringent programmatic  
          requirements associated with the independent nature of a THPP,  
          rather than the more structured group home requirements.  It is  
          also unclear how the program will provide for the youth during  
          holidays, spring and summer break, and other times when the  
          youth will not be in school. The bill also exempts the pilot  
          program from having to adhere with current THPP requirements if  
          they are deemed to be in conflict with the pilot.  As written,  
          this could be construed to allow the program to be exempt from  
          most requirements as the program is structured as a group care  
          program and not an independent living placement. 

          In contrast to the sponsors' own statement on the purpose of the  
          program, including that "the Academy will enhance the  
          possibilities of reunification or permanent adoption for our  
          students, because they will visibly improve academically,  
          behaviorally and in the caliber of their hopes and dreams," they  
          further state that, under the program, if a foster youth is  
          "adopted or reunified during the four years of high school  
          (they) will be offered enrollment in the parallel BGA summer  
          academy."  This creates ambiguity as to the purpose and goals of  
          the pilot program. On the one hand, the program would be  
          tailored towards making reunification or permanency for foster  
          youth a greater reality, but on the other, once permanency is  
          achieved, they would be removed from the program and placed into  
          the summer program, thus cancelling out the purpose of improving  
          the youth's opportunity of becoming qualified to go to college.   
          Additionally, it is contrary to the intent of Section 48853.5 of  
          the Education Code established by AB 1933 (Brownley) Chapter  
          563, Statutes of 2010, which extended the right of foster youth  
          to remain in their school of origin from the remainder of the  
          school year (after changing residential placement) to the  
          duration of the jurisdiction of the court.

          Lastly, the bill lacks details on whether foster youth placed  
          into the program will attend the same high school or whether the  
          school should be required to provide additional supportive  
          services for the foster youth.  Although implicit in the bill,  
          it does not provide specific protections that the youth will be  
          able to attend their school of enrollment or whether they should  
          be removed and transferred to a school in closer proximity to  









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          the residential component.  It is also unclear on what type of  
          relationship would be established between the program and the  
          local educational agency, whether it comes with individualized  
          services and supports tailored to the unique needs of each  
          foster youth, and whether transportation services would be  
          provided if the foster youth attend the same or different  
          schools.  

           RECOMMENDED AMENDMENTS:  

          Due to the number of issues with the bill, committee staff  
          recommends substantially amending the bill to align the program  
          within existing programmatic allowances.  Specifically, the  
          amendments would do the following:

          1)Clarify that the pilot may be awarded to any county CWA that  
            enters into a memorandum of understanding (MOU) with a public  
            university, county mental health department and local  
            educational agency to operate the pilot.

          2)Require the MOU to include financial and programmatic  
            commitments from each entity required to sign the MOU, which  
            shall include specific roles and responsibilities for each  
            entity. 

          3)Clarify eligibility for the program to be limited to only  
            those foster youth who are no longer receiving family  
            reunification services and have been in group care for three  
            consecutive years.

          4)Clarify that DSS shall select the local county that will  
            operate the pilot.

          5)Clarify that the pilot shall operate as a THPP within the  
            current structure of the THPP program, thus limiting the  
            residential component to foster youth who are 16 and 17 years  
            of age. 

          6)Provide that the pilot ensure the continued provision of  
            permanency services, such as adoption and guardianship  
            services.

          7)Provide that a youth who reaches permanency may remain in the  
            pilot if agreed to by the youth and the youth's parent(s),  
            guardian(s), or adoptive parent(s).









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          8)Provide that supportive services may continue if the youth  
            becomes a nonminor as specified in his or her case plan.

          9)Provides that 14 and 15 year old foster youth may participate  
            in the program through the provision of wraparound services  
            and supports, but may not be placed into the residential  
            component.

          10)Provide a clearer timeline for the implementation and  
            termination of the pilot.

          11)Delete the authority for the funding allocation rate to be  
            160 percent of the current THPP rate, and clarify that any  
            additional costs beyond the current THPP rate are borne by the  
            county CWA or supported by philanthropic funding. 

          12)Require DSS to conduct an interim evaluation report, in  
            addition to the already required final evaluation report that  
            is required to be submitted to the Legislature. 


































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           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          First Star 
          Juvenile Court Judges of California 
          Housing California 
          University of California (UC) 

           Opposition 
           
          Youth Law Center 
           
          Analysis Prepared by  :    Chris Reefe / HUM. S. / (916) 319-2089