5101:2-9-42 Qualified Residential Treatment Program (QRTP).

Very concerned that tying QRTP requirement to licensing will end up limiting options for child placement across the state of Ohio.

Agencies certified after October 1, 2020 are to be compliant with this rule in order to become certified. >>>>>"certified" twice in the same sentence creates lack of clarity of the meaning. Agencies certified prior to October 1, 2020 have until October 1, 2024 to become compliant with the requirements related to meeting QRTP standards. >>>>>> >all of the agencies who are not compliant between 10/01/21 and 10/1/2024 will NOT be IV-E reimbursable...if so, this will create incredible financial burden for Counties. In order to maintain title IV-E reimbursability, residential agencies must meet QRTP standards by October 1, 2021.

We have many questions around how some of the requirements will be monitored by the licensing authorities. For example, some terms around trauma informed care are quite vague. If a provider is determined to consistently not achieve those goals, will they lose their QRTP status? Could they keep their license and just not be a QRTP, or would they cease to be able to operate? Or, we could choose to place there but wouldn’t be reimbursed? What does that look like?

We echo Jewell Good's existing comment - If a residential provider does not choose/cannot meet QRTP criteria until 2024 under the phase-in approach, and IV-E is required by 2021, are we to assume as PCSA’s that we will shoulder the burden of those costs/lack of reimbursement? If so, that cost shift could be gravely problematic.

This requirement will substantially increase costs of placements -" accessible on-site or face-to-face to meet the child’s clinical and/or medical needs." 24/7 days a week . Currently many facilities have on-site clinical staff available 24/7, but many programs do not have after hours medical staff. This requirement as it stands will simply increase program costs, that will be passed onto CSB's and Courts. We understand that there needs to be 24/7 availability, but perhaps examining the "on-site or face to face" accessibility sentence to open up more options for residential agencies to be able to achieve this requirement including telehealth options.