July 1, 2020 Ross Hunter Secretary Department of Children Youth and Families Cc: Frank Ordway, Sydney Forester, Steve Grilli, Kwesi Booker and Luba Bezborodnikova Dear Secretary Hunter, On behalf of the Washington Association for Children and Families (WACF) members that provide Behavioral Rehabilitation Services (BRS), specifically group homes and qualified residential treatment programs (QRTP), we would like to voice concern about DCYF’s response related to youth and/or staff who test positive for the COVID virus in a group care setting. Starting in March, at the onset of the COVID crisis, we have consistently voiced concern with DCYF staff about the challenges group homes would face in the event of an outbreak of the COVID virus. We have made requests to DCYF to partner with agencies in emergent planning. Until recently, when we began incorporating the Department of Health in planning, DCYF did not seem to recognize the unique challenges our agencies would face in the event of an outbreak. It is imperative the concerns are understood and that we work together for viable solutions to serve youth, while preserving agency resources, through this pandemic. The list of concerns are: o Youth Quarantine Needs: DCYF’s expectation that youth should be isolated or quarantined in their rooms regardless of the behavioral challenges of the youth we serve. “Despite DOH’s guidance, which states that in group care settings, because residents often have a significant history of trauma, it will be important to work with local public health to develop the best trauma-informed strategies for quarantine and isolation. This may require alternate strategies to retaining youth in a room for isolation and quarantine”. And, agency staff simply cannot physically make a youth quarantine in their room, which would expose COVID free and healthy staff and youth. o Staffing Resources: Agency concerns have been shared repeatedly that the inability to staff a program could come swiftly in an outbreak and/or youth would need alternate safe placement quickly. DCYF’s suggestions to agencies to staff programs in an outbreak are further concerning: ▪ DCYF expects those staff members to keep working if sick. This is in direct opposition of public health directive and the CARES ACT. Agencies must adhere to the CARES Act which allows for staff who have been potentially exposed to quarantine at home with family, with pay. ▪ Staff Quarantine On-site: DCYF has suggested staff quarantine at the facility. This will not be possible at most group homes. This is also contrary to DOH’s guidance to quarantine for 14 days if tested positive or if an individual may have been exposed other individuals who test positive. ▪ Set up trailers on-site for staff: This solution also contradicts DOH and DCYF’s WAC of what is expected to provide staff with respect to breaks. This also poses liability concerns for providers. ▪ Agencies immediately hire staff from DCYF staffing pool: The staffing pool has been proactively accessed by a few agencies; but the expectation is that agencies hire staff from that list on the spot if an outbreak were to occur. We have consistently voiced that we are unable to do that due to many varying hiring policies of agencies. The staffing pool does not provide sufficient numbers of viable applicants specifically people that are willing to work in a group facility, none of the applicants in the Spokane area are viable options. ▪ DOH Response: DOH has communicated that the likelihood of asking staff to continue working during an outbreak is very slim, and contradicts DOH general testing response. o Group care is not a medical facility: Returning youth who test positive to an environment where medical PPE is not available is unsafe and, it is impossible to keep youth wearing the PPE. o Youth Rights: Youth have rights. Should a youth test positive and be expected to return to the facility, the other youth who reside in the home have the right to consider their own risk of whether they want to be placed with other youth who are positive or exposed. Our concerns have been shared repeatedly. If staff are unable to come to work then quarantining youth in place may not be possible, even if it were determined they could be kept in place. In the case of Spruce Street, DCYF expected them to hire staff from the list despite our repeated discussions that agencies would be unable to do so. Again, while the list was appreciated, it has not been a good resource and it is unrealistic to expect agencies to sort through the list to be able to hire on the spot. The key to all of this is having a stable workforce during the pandemic. This means having an environment where staff are able and WILLING to come to work every day. The risks and stresses for staff are significant and they need to know their agency will advocate for their health and safety above all else. For them to potentially be required to work while ill puts their immediate family at risk. This is unreasonable and is a standard that DCYF is not imposing on their own staff. The pandemic brings multiple complications to all sectors and the solutions are not a one size fits all. DCYF’s general expectation for all cases is that agencies must be able to keep youth in place is unrealistic. We have had three cases in member’s group homes and all three were extremely different and public health’s response was quite different. In the Seattle Times article on June 21st it stated, “DCYF has since stopped placing children at Spruce Street, saying it only uses facilities that can meet our required duty to provide services.” Many agencies perceived this to be retaliation for an agency’s inability to quarantine youth in place and have expressed concern and worry about their own programs. Our agencies, our Boards of Directors and our employees are all watching the events impacting the Pioneer programs with great interest and concern. Is this a partnership and collaboration or is it vendors providing blind service to a contract with the State while in an unprecedented global pandemic? The understanding and partnership through this has been very poor and ultimately resulted in one agency no longer having youth placed in their home permanently. There have now been three incidents in group homes all with different situations it is reasonable to think that there would be challenges, it is also reasonable to ask for a collaborative process with DCYF to work together to better inform and prepare for other potential outbreaks. Losing 18 beds, in a time when we can’t afford to lose any beds because of the number of kids in hotels and the lack of beds on the west side of the state seems unwarranted and not in the best interest for children. We aim to preserve all existing beds, preserve all staffing resources, and respond to the needs of the youth with the utmost care and urgency during this pandemic. Agencies must do so while equally adhering to WAC, DOH, Public Health, CARES Act and DCYF expectations collectively. We need DCYF to understand the concerns, the barriers we anticipate, and collectively work on solutions to sustain these resources and safely serve our youth. We look forward to your response and to working together in partnership to provide a safe environment for the youth in our care and the staff that support these youth. Sincerely, Jill May Executive Director WA Association for Children and Families