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© Copyright 2008 Nan McKay & Associates
Managing the FSS Program
with Patti Zatarian Menardwith Patti Zatarian Menard
© Copyright 2008 Nan McKay & Associates
Managing the FSS Program
© Copyright 2008 Nan McKay & Associates
3
© Copyright 2008 Nan McKay & Associates
Overview Program StepsDevelop PCC
Identify & coordinate needs to resources
Develop Action PlanRevise Action Plan
ACO
Develop program designService systems
Select & service participants
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© Copyright 2008 Nan McKay & Associates
FSS Program DesignPlanning
Outreach
Orienting
Assessing Needs & Setting Goals
Selecting
Contracting
Servicing
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© Copyright 2008 Nan McKay & Associates
Case Managing & Support Services
Escrowing and Porting
Monitoring & Evaluating
Reporting
Program Evaluation Quantitative Qualitative
FSS Program DesignServicing
Managing the FSS Program
Action Plan Program Coordinating
Committee Escrow Accounts Case Workers
© Copyright 2008 Nan McKay & Associates
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© Copyright 2008 Nan McKay & Associates
FSS Coordinator Activities Develop program needs assessment Identify realistic program outcomes Design FSS program Develop FSS case management record systems Match FSS program’s needs and goals to
existing services in community Develop new community services Develop and maintain program outcomes
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© Copyright 2008 Nan McKay & Associates
Case Manager Activities
Develop and manage effective Individual Training & Service Plans by: Conducting orientations and intake interview Assessing skills, abilities, needs & resources Identifying realistic goals, develop tasks to
accomplish goals Monitoring and documenting progress Completing CM relationships of FSS
participants
Managing the FSS Program Know the Basics Clarify the Basics Identify Common Mistakes Identify Best Practices
© Copyright 2008 Nan McKay & Associates
Managing the FSS Program
Know the Basics
© Copyright 2008 Nan McKay & Associates
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© Copyright 2008 Nan McKay & Associates
FSS BASICS
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© Copyright 2008 Nan McKay & Associates
Family Self SufficiencyProgram Goals
Matching Housing Assistance Families
with
Existing Community Services
to
Achieve Economic Self Sufficiency
Managing the FSS Program
Clarify the Basics Identify Common Mistakes Identify Best Practices
© Copyright 2008 Nan McKay & Associates
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© Copyright 2008 Nan McKay & Associates
FSS Regulations Clarification
Families can Complete FSS without
reaching economic self sufficiency
Complete with less money than when started
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© Copyright 2008 Nan McKay & Associates
FSS Best Practice
Identify what PHA is trying to accomplish in FSS program Get people a job any job Move families toward self
sufficiency Decrease HAP dependence
increase rent roll What does your Logic Model
say?
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© Copyright 2008 Nan McKay & Associates
FSS Common Mistakes Implementing FSS
without considering goal Implementing FSS
without matching goal to PHA goals
Not telling FSS Coordinator goal
Completing Logic Model without staff input
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© Copyright 2008 Nan McKay & Associates
HUD References
24CFR Part 984, SubParts (A)(B)(C)(D) PIH Notice 93-24, Q & A’s PIH Notice 95-5 Modification of Contract FSS Contract of Participation FAQs
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© Copyright 2008 Nan McKay & Associates
HUD Regulations (M & M’s)
The PHA must… The PHA shall…
The PHA may not… The PHA shall not…
No Choice: Do It!
Prohibited: Can’t Do It !
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© Copyright 2008 Nan McKay & Associates
HUD Regulations (M & M’s)
PHA may = Choice Choice = Policy Policy =
FSS Action Plan ACOP or Administrative Plan
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© Copyright 2008 Nan McKay & Associates
PHA Policy
Agency Plan
AnnualPlan
Admin & OCC Plan
Action Plan
Admin Plan
Action Plan
© Copyright 2008 Nan McKay & Associates
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© Copyright 2008 Nan McKay & Associates
Action Plan Requirements
Must have a HUD-approved Action Plan to operate an FSS program
Developed with PC and CEO of Gov’t PHA final decision-maker
Must include revisions in Annual Plan
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© Copyright 2008 Nan McKay & Associates
Minimum Required Contents
24 CFR 984.__ Action Plan must include Demographics Selection Procedures Incentives Activities Termination Procedures Timetable Assurances
Non Interference Coordination
Managing the FSS Program
Clarify the Basics Identify Common Mistakes Identify Best Practices
© Copyright 2008 Nan McKay & Associates
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© Copyright 2008 Nan McKay & Associates
FSS Regulations Clarification
FSS Action Plan is the only policy for FSS
All “mays” must be clarified in Action Plan
Any undefined words must be defined in plan
Action Plan must be up to date, approved by Board, followed exactly
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© Copyright 2008 Nan McKay & Associates
FSS Best Practice Create an Action Plan
“Boiler” to work in by highlighting Every “may” Every word or phrase not
clearly defined in regulation and
Everything regulation says “must” be in policy
Then….
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© Copyright 2008 Nan McKay & Associates
FSS Best Practice
Make a “Word” document using the bold headings from the regulation
Fill in each one of the policy decisions that needs to be made
Take this list to PCC first for recommendations
Take the list and recommendations to management
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© Copyright 2008 Nan McKay & Associates
FSS Common Mistakes
Working from an old and insufficient Action Plan
PHA makes all decisions without any vocational expertise
FSS Coordinator makes all decisions without vocational expertise
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© Copyright 2008 Nan McKay & Associates
PROGRAM COORDINATING COMMITTEE
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© Copyright 2008 Nan McKay & Associates
PROGRAM COORDINATING COMMITTEE
Must establish a PCC: Can establish own or use existing entity (ex: WIA)
Assists With Program PHA Accountable Must include:
HCV Participant PH resident: resident council or other resident
group PHA Representative
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© Copyright 2008 Nan McKay & Associates
Other Possible Members
Who else…………?
Childcare
Employ
Legal
Fund-raising
Religious
Political
Financial
Entrepreneurship
Law enforcement
Marketing/Media
Social work
Case management
Homeownership
Managing the FSS Program
Clarify the Basics Identify Common Mistakes Identify Best Practices
© Copyright 2008 Nan McKay & Associates
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© Copyright 2008 Nan McKay & Associates
FSS Regulations Clarification
Must have PCC with appropriate members
Nothing else about PCC is regulated
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© Copyright 2008 Nan McKay & Associates
FSS Best Practice FSS Coordinator makes PCC their #1
concern PCC membership from
Community College Adult Basic Education Workforce Investment Board Career Center Community Based Organizations w/ WIA
Funding Dept Health & Human Services United Way City or County
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© Copyright 2008 Nan McKay & Associates FSS Program Coordinating
Committee
Social Policy
Law
Regulations
DOE DOL DHUD DHHS DOT
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© Copyright 2008 Nan McKay & Associates
FSS Best Practice
PCC Members are policy makers
PHA rep is policy maker Chair of PCC is leader in
community PCC is a group of experts FSS Coordinator “staffs”
PCC
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© Copyright 2008 Nan McKay & Associates
FSS Best Practice At first or renewing PCC
meeting Explain the goal of FSS Ask PCC members # of their
clients w/ S8 or PH assistance
Describe S8 and PH families Ask what it would take for
them to get SS wage jobs in 5 years
Brainstorm Plan
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© Copyright 2008 Nan McKay & Associates
FSS Common Mistakes
No PCC FSS Coordinator chairs meeting
Group doesn’t know they share clients
Group doesn’t see WIFM FSS Coordinator doesn’t network, network, network
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© Copyright 2008 Nan McKay & Associates
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© Copyright 2008 Nan McKay & Associates
Denial of Participation
May deny FSS participation to: People who are not
motivated Previous participant who was
terminated Families where services are
unavailable Participants and residents
who owe debt to any PHA
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© Copyright 2008 Nan McKay & Associates
FSS CONTRACT OF PARTICIPATION
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© Copyright 2008 Nan McKay & Associates
FSS CONTRACT
Must execute COP -HUD Form 52650 ITSP must be completed for head Must be signed by family head Initial term 5 Years
Effective 1st day pf month after signing Can be extended up to two years for “good
cause” beyond family control May extend to help family meet the 12
consecutive month welfare-free requirement
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© Copyright 2008 Nan McKay & Associates
INDIVIDUAL TRAINING AND SERVICE PLAN
Mandatory for Head Optional for other family members if PHA agrees Must Attach to Contract Final Goal: Suitable Employment Interim Goal: All members welfare-free 12
consecutive months prior to expiration Includes Interim Goals and Incentives Any changes included as a written revision
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© Copyright 2008 Nan McKay & Associates
FSS CONTRACT
Contract May Be Modified:1. ITSP2. Contract Term3. New FSS Head
4. Eliminate termination line
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© Copyright 2008 Nan McKay & Associates
This is serious business
COMPLIANCE WITH LEASE
FSS Contract requires Compliance with program
lease Compliance with Family
Obligations contract PHA may terminate FSS
Contract for... non-compliance with lease
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© Copyright 2008 Nan McKay & Associates
SEEK AND MAINTAIN EMPLOYMENT
Requirement for FSS head only PHA must define “seek” PHA determines suitability of employment
No minimum time period the Head needs to be employed
Only head required to obtain employment
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© Copyright 2008 Nan McKay & Associates
Interim Escrow Disbursements
At sole discretion of PHA If family has completed certain interim
goals, and PHA determines funds consistent with
contract and needed for completing goals (ex: job training, tuition, business start-up)
Managing the FSS Program
Clarify the Basics Identify Common Mistakes Identify Best Practices
© Copyright 2008 Nan McKay & Associates
49
© Copyright 2008 Nan McKay & Associates
FSS Regulations Clarification
Must define in Action Plan Extensions for good cause Seek and maintain employment Suitable employment Interim disbursements
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© Copyright 2008 Nan McKay & Associates
FSS Best Practice
Extensions if an extension means more earnings
Seek and maintain definition that allow education or training
Interims that get money needed to meet goals
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© Copyright 2008 Nan McKay & Associates
FSS Common Mistakes
Making arbitrary escrow and term policies
Using escrow simply as a reward
Setting policies so tight that forfeitures are likely
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© Copyright 2008 Nan McKay & Associates
You go!!!
COMPLETION OF THE FSS CONTRACT
All obligations complete on or before expiration of FSS contract…or
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© Copyright 2008 Nan McKay & Associates
Cut the escrow check!
COMPLETION OF THE FSS CONTRACT
30% AMI equals/exceeds FMR, AND
Head certifies family welfare free
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© Copyright 2008 Nan McKay & Associates Consequences of Non-Compliance with FSS
Contract
Withhold supportive services Terminate FSS participation Terminate S8 assistance (unless only
basis is failure to become welfare-free)
PHA never “required” to terminate assistance for FSS non-compliance
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© Copyright 2008 Nan McKay & Associates
TRANSITIONAL SERVICES
Transitional Services If head is employed
FSS COP may be terminated: Mutual consent Failure to meet obligations Withdrawal
FSS family is entitled to grievance hearing
Managing the FSS Program
Clarify the Basics Identify Common Mistakes Identify Best Practices
© Copyright 2008 Nan McKay & Associates
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© Copyright 2008 Nan McKay & Associates
FSS Regulations Clarification
Must have policies that make it clear when a missed goal results in Changed ITSP More case management Withheld services Termination
Policy can not be arbitrary or discriminatory
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© Copyright 2008 Nan McKay & Associates
FSS Best Practice
Always best to start with case management first
Remember They volunteered Its their dream We need them to work
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© Copyright 2008 Nan McKay & Associates
FSS Common Mistakes
No policy at all Each case manager
deciding each case Not getting guidance
from PCC
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© Copyright 2008 Nan McKay & Associates
ESCROW ACCOUNTS
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© Copyright 2008 Nan McKay & Associates
How the Escrow Account Works
Generally, escrow credit is amount that family’s rent increases as result of increase in earned income
Families continue to pay increased rent Must use HUD formula Amount of escrows depends on income level
(very-low Vs. low) Let’s see…..
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© Copyright 2008 Nan McKay & Associates Income and Rent Calculations
“BASELINE FIGURES”
Annual income, earned income and family rent entered into contract
Taken From Last Recertification..…
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© Copyright 2008 Nan McKay & Associates
Baseline Figures
Unless…more than 120 days elapsed Then must conduct interim
Escrow is triggered by increases in earned income, not unearned income
Increase in earned income of any adult family member…. Not just FSS head
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© Copyright 2008 Nan McKay & Associates
Timing of Escrow Calculations
At time of contract, enter baseline figures No escrow until an increase in earnings is
included in annual income After effective date of contract PHA will
calculate credit At every annual and interim reexamination When there is earned income received by an adult
family member When there is a change in earned income
Remember…PHA policy sets effective date
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© Copyright 2008 Nan McKay & Associates
Effects of Earned Income Disregard (EID)
Earned income that is not included in family’s annual income due to EID will not be counted in calculation of escrow
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© Copyright 2008 Nan McKay & Associates
Where Does The Escrow Come From In Public
Housing FSS? Rental Income!!!
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© Copyright 2008 Nan McKay & Associates
In Section 8?
PHA Share to LL (HAP)
Family Share to LL
Escrow
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© Copyright 2008 Nan McKay & Associates
Crediting the Escrow
Deposit in single account for each FSS program
Track each family on subsidiary ledger Credit, post interest, and report to family
not less than annually Credits are based on actual rent paid No retro credits for families who don’t report
increases
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© Copyright 2008 Nan McKay & Associates
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© Copyright 2008 Nan McKay & Associates
Forfeiting Escrow Account
Contract terminated Completed but family receiving welfare If head dies and remaining members choose not
to participate Forfeited Funds
Section 8: treated as program receipts for payment of program expenses (HAP payments)
PH: credited to PHA operating reserves and counted as “other income” in next budget year
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© Copyright 2008 Nan McKay & Associates
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© Copyright 2008 Nan McKay & Associates
Disbursing FSS Account
Final Disbursement…. When
Family fulfills all obligations under contract
or 30% MAI =/> FMR
Subtract from Escrow… dollars owed the PHA and pay out balance
Managing the FSS Program
Clarify the Basics Identify Common Mistakes Identify Best Practices
© Copyright 2008 Nan McKay & Associates
74
© Copyright 2008 Nan McKay & Associates
FSS Regulations Clarification
Completion is 30% MAI =/> FMR
NOT Zero HAP
Must have interim if more than 120 days
May not issue 1099 on escrow
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© Copyright 2008 Nan McKay & Associates
FSS Regulations Clarification
Must reduce escrow balance by $ owed under the lease before posting interest
Must reduce escrow by $ owed PHA before final distribution
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© Copyright 2008 Nan McKay & Associates
FSS Best Practice Do the basics! Work closely with finance Work using the
regulations from both FSS and Finance as well as
Policies and procedures for paying accounts payable
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© Copyright 2008 Nan McKay & Associates
FSS Common Mistakes
Not working with finance FSS left out of the loop! Incorrect information to
finance
Managing Case Managers in the FSS
Program
Know the BasicsProgram Design
© Copyright 2008 Nan McKay & Associates
79
© Copyright 2008 Nan McKay & Associates
FSS Coordinator Activities Develop program needs assessment Identify realistic program outcomes Design FSS program Develop FSS case management record systems Match FSS program’s needs and goals to
existing services in community Develop new community services Develop and maintain program outcomes
80
© Copyright 2008 Nan McKay & Associates
Overview Program StepsDevelop PCC
Identify & coordinate needs to resources
Develop Action PlanRevise Action Plan
ACO
Develop program designService systems
Select & service participants
81
© Copyright 2008 Nan McKay & Associates
FSS Program DesignPlanning
Outreach
Orienting
Assessing Needs & Setting Goals
Selecting
Contracting
Servicing
82
© Copyright 2008 Nan McKay & Associates
Case Managing & Support Services
Escrowing and Porting
Monitoring & Evaluating
Reporting
Program Evaluation Quantitative Qualitative
FSS Program DesignServicing
83
© Copyright 2008 Nan McKay & Associates
FSS Support Services
Voc Assessment Ed Assessment Career Exploration Voc/Ed Planning Job Training Education Tutoring
Life Skills Support Groups Community Activities Job Search
Assistance Resources:
Child Care Transportation Medical
Managing Case Managers in the FSS
Program
Clarify the Basics Identify Common Mistakes Identify Best Practices
85
© Copyright 2008 Nan McKay & Associates
FSS Program Design Clarification
HUD doesn’t regulate FSS program design
Logic Model is PHAs own creation and includes activities in program design
Design is based on PHAs goal for the program
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© Copyright 2008 Nan McKay & Associates
FSS Program Design Clarification
Outreach, orientation, needs assessment, and goal setting are separate activities
87
© Copyright 2008 Nan McKay & Associates
FSS Common Mistakes
Designing the FSS program without vocational expertise From PCC From expert staff
Designing the FSS program based on myths about the hardest serve GED is a necessary 1st step People who don’t follow
through aren’t motivated
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© Copyright 2008 Nan McKay & Associates
FSS Best Practice Use PCC as experts in
employment services Develop FSS program
using referrals to already existing employment services
Put emphasis on FSS Coordination rather than on case management
Managing Case Managers in the FSS
Program
Know the BasicsCase Management Design
90
© Copyright 2008 Nan McKay & Associates
Case Manager Activities
Develop and manage effective Individual Training & Service Plans by: Conducting orientations and intake interview Assessing skills, abilities, needs & resources Identifying realistic goals, develop tasks to
accomplish goals Monitoring and documenting progress Completing CM relationships of FSS
participants
Managing Case Managers in the FSS
Program
Clarify the Basics Identify Common Mistakes Identify Best Practices
92
© Copyright 2008 Nan McKay & Associates
FSS Case Management Clarification
HUD doesn’t require FSS programs to provide any or all of the case management services
HUD doesn’t regulate file documentation
PHAs may partner for any or all of the case management
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© Copyright 2008 Nan McKay & Associates
Case Manager Activities
Develop and manage effective Individual Training & Service Plans by: Conducting orientations and intake interview Assessing skills, abilities, needs & resources Identifying realistic goals, develop tasks to
accomplish goals Monitoring and documenting progress Completing CM relationships of FSS
participants
94
© Copyright 2008 Nan McKay & Associates
FSS Case Management Clarification
Really two types of monitoring progress in case management Have you completed this
task or interim goal? What can we do to help?
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© Copyright 2008 Nan McKay & Associates
FSS Common Mistakes
Developing ITSPs from a conversation between the FSS HOH and the case manager
Providing FSS case management services without training and expertise on how to do so….
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© Copyright 2008 Nan McKay & Associates
FSS Best Practice
Refer for assessment, goal setting, and monitoring when completing a task or goal is a problem
Place emphasis on PCC and referrals rather than direct case management service
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© Copyright 2008 Nan McKay & Associates
FSS Best Practice Develop clear
procedures for file documentation and tracking services, completion of tasks, challenges, and outcomes
Use this information to inform PCC
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© Copyright 2008 Nan McKay & Associates
FSS Best Practice Build strong case
management relationships with FSS families and then partner as they use referral sources
Collaborate for services with PCC so families can succeed
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© Copyright 2008 Nan McKay & Associates
NMA Upcoming Lunch ‘n’ Learns… The HAP Contract, the Lease, the RFTA
November 7, 2008 Managing EIV
November 14, 2008 Community Service
November 21, 2008
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