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Voices Speaking

October 17, 2018

Public Charge Open for Comments: Rule change would discourage non-citizens from using social services

Karen Siegel, M.P.H.

A few weeks ago, we posted about the “public charge” determination and proposed changes to this rule. The comment period on this rule change began this week and is open until December 10.

Specifically, how would the “public charge” determination change?

The proposed changes would continue to rely on “totality of circumstances” in making immigration decisions. However, they would:

  • Change the threshold from an applicant being “primarily dependent on” to being “likely to receive” a public benefit

  • Expand the list of benefits considered to include Medicaid, SNAP, housing assistance, and more

  • Consider factors such as health, age, and English proficiency

  • Impose a specific income test that makes those earning less than $26,000/per year for a family of three less likely to be approved

These changes include a complex set of rules designed to disqualify immigrants of low to moderate income and favor those with higher incomes (over $52,000/year for a family of 3). The “public charge” determination is considered when a lawfully present immigrant applies for a change in status (for example when applying to change from a student visa to Lawful Permanent Resident status or “green card” holder, or when a “green card” holder leaves the country for more than 180 days and seeks to reenter). See these scenarios explaining when and to whom these rules apply.

The end result will most likely be children and families going without health insurance and other key supports for fear of repercussions, whether or not the rules apply to their circumstances.

How would these changes impact children in Connecticut?

Connecticut’s current laws and rules provide extremely limited access to social services and public health insurance for non-citizens. Nonetheless, there are reports that the rule is already causing confusion, fear, and disenrollment. In Connecticut, an estimated 87,000 children who have at least one non-citizen parent live in families enrolled in a benefit program such as Medicaid (our state’s HUSKY program) or SNAP.  Even though very few of those families would be subject to a public charge determination, the rules are confusing. As a result, the state’s rate of families without insurance or access to adequate nutrition is likely to increase.

Connecticut Voices for Children will submit comments to the federal register and will share our comments here.

Take Action:

Issue Area:
Benefits, immigration, Medicaid, public charge, SNAP
October 16, 2018

Meeting the Complex Needs of Youth in State Residential Facilities

Stephanie Luczak, LMSW and Lauren Ruth, Ph.D.

The needs of youth who have experienced multiple traumas are complex and impact their physical health, education, behavioral health, and family stability. Children who have complex needs easily fall through systemic cracks or experience unmet needs.

On September 26th, 2018, the Connecticut Office of the Child Advocate (OCA) released a report regarding the state-run Psychiatric Residential Treatment Facility at the Albert J. Solnit South Center Campus (Solnit S.). Three months prior, a 16-year-old, known as Destiny, died by suicide in the facility. Destiny was both pregnant and in in the care of the Department of Children and Families (DCF) at the time of her death.

The OCA report and a subsequent legislative informational hearing provided insight into three main systemic issues:

  1. Adolescents, particularly those with a history of trauma and those committed to DCF, have complex mental health needs. The systems that serve these youths must be equipped to adequately serve those needs.

  2.  The assessment and monitoring of residential facilities for youth, including Solnit, must promote increased transparency, timely reporting, public access to these reports, and be an ongoing practice.

  3. There is a need for a legislative oversight council to help facilitate accountability, improve policy and practice, and increase cross-agency coordination to improve outcomes for children and their families.

The OCA report examines a brief timeline of events leading up to Destiny’s death, including Destiny’s historical trauma and presenting mental health needs, and identifies several risk factors that were present at the time of Destiny’s admission to Solnit S. It also provides an in-depth look at the systemic issues that increased youths’ risk of attempting suicide at Solnit, including Destiny, as well as seven other attempts that occurred between November 2017 and July 2018.

The report states that Destiny experienced the trauma of maltreatment during early childhood, after which guardianship was transferred to a relative when she was two years old. Experiencing childhood trauma increases the risk of negative lifetime impacts including suicidal thoughts and behaviors. A 2013 literature review examined several studies that explored the relationship between child maltreatment and adolescent suicidal ideation and attempts. The 2013 article determined that there is a clear link between childhood sexual abuse, physical abuse, emotional abuse, and neglect and suicidal thoughts and behavior (p. 12-13). While the harmful impacts of trauma compound with exposure to new traumas, clinical interventions, increased social support, and positive coping mechanisms can successfully decrease suicidal ideation among adolescents who have been maltreated (p. 22).

Destiny was committed to DCF in October of 2016 when her mental health needs exceeded her caregiver’s capacity. From that date until her commitment to Solnit S. in February of 2018, she moved frequently from place to place including a group home, a foster home, and multiple stays in congregate care (p. 19-20). Separation from caregivers, such as when children enter foster care, is a traumatic experience that has been linked to increased risk for depression and other psychopathologies including suicidal ideation and behaviors., the federal website that promotes effective youth programs and resources, reports that: “children in foster care were almost three times more likely to have considered suicide and almost four times more likely to have attempted suicide than those who have never been in foster care.”

Destiny attempted to end her life in September of 2016, one month prior to entering DCF care. Prior to her admittance to Solnit S., Destiny had expressed suicidal ideation multiple times, as stated in the DCF record (p. 20).

Although the American Foundation for Suicide Prevention lists previous suicide attempts as a risk factor that may increase the chance of future suicidal thoughts or behaviors, upon Destiny’s admission to Solnit S., she was “considered a low risk for suicidal attempts, self-injurious behavior or assaults” (p. 20). This was a clear miscategorization because Destiny’s history of trauma, commitment to DCF, and prior suicide attempts collectively indicate a moderate to high-level risk for suicidal behavior, according to the Columbia Suicide Severity Rating Scale (C-SSRS).

Youth suicide is a devastating tragedy that continues to be the second leading cause of death for young adults ages 15-34, both in Connecticut and nationwide. However, it is also preventable in many cases.

Suicide prevention begins with promoting a process for understanding, screening, and treating suicidal ideation and behavior, made possible through increased education and communication about youth suicide. This includes the use of consistently and regularly administration of the Columbia Suicide Severity Rating Scale (C-SSRS) across state and private agencies, in congruence with the State of Connecticut’s Suicide Prevention Plan 2020 (p. 25). The C-SSRS is a widely-used scale that screens for risk of suicide and is supported by an “unprecedented” amount of research.

The C-SSRS has been widely supported and utilized within the mental health field. However, it is unclear how the scale was administered at Solnit S. Barrins & Associates—the independent consultants hired by DCF to examine the facility. They found that “the regular use of the C-SSRS is relatively new at Solnit South, and staff may not have developed the habits that facilitate its use” (p. 19). The September 20th report from Barrins & Associates goes on to further recommend that Solnit S. should prioritize and measure compliance with the use of the C-SSRS administration and documentation. Additionally, preceding Barrins & Associates reports from September 19th and August 28th, found that “risk assessments completed on admission are sometimes confusing, the form is ineffective in determining level of risk,” (p. 6) and “the policy governing the administration of the C-SSRS is not clear and appears to be internally contradictory” (p. 4).

It is unclear how the C-SSRS is administered at Solnit S., and it is also uncertain how the facility plans for youths’ discharge. DCF Commissioner Katz pointed out during her testimony that while hundreds of cases have been successfully discharged from Solnit S., all youth who are discharged from the facility must have adequate therapeutic, educational, and social supports in place to meet their needs so that they can thrive in the community.

The OCA report provides illuminating evidence that Destiny’s discharge was not carefully planned. The report makes clear that neither mental health services nor a clear educational plan were in place or communicated to the foster placement. (p. 23). This lack of discharge planning can provide for tumultuous placement change, which is a problem that is not unique to the Solnit S. facility. During Connecticut Voices for Children’s 7th Annual Youth at the Capitol Day event, youth currently in foster care in Connecticut discussed several experiences of moves with a lack of planning. When the youth were asked about what would make the placement change process smoother, they unanimously expressed that being given more time and information makes for a smoother and more positive transition.

In addition to the recommendations proposed by both the Office of the Child Advocate and Barrins & Associates, the systemic failures, in this case, provide further support for the need of an independent, legislative oversight council to improve outcomes for children and families in vulnerable situations across the state. The OCA report identifies that although the current DCF State Advisory Council (SAC) requires DCF to report information regarding facilities, including Solnit S., no reports have been made available on the SAC website (p. 11). An independent legislative oversight council would not only increase agency oversight, but it would convene a multidisciplinary group to “monitor, track, and evaluate DCF’s policies and practices,” such as the policy of administering the C-SSRS at Solnit S., or improving the coordination of discharge planning across agencies.

In some cases, like Destiny’s, the inability to identify a need and provide services can result in tragedy. Connecticut must do better in serving children with complex mental health needs and the families who care for them. This can be done by decreasing agency silos and working more collectively to improve how our systems support children with complex needs through an increase in systemic accountability, transparency, and collaboration.

Issue Area:
Child Welfare
DCF, mental health, trauma