Generations United urges the Biden Administration to take bold steps to invest in innovative and proven strategies that address pressing challenges facing our nation’s children, youth, older adults and families. To respond to our nation’s long-standing challenges and the health, mental health and economic impacts of COVID-19, Generations United urges the use of approaches that recognize and engage the time and skills of our nation’s younger and older people as resources to each other and their communities. The administration must engage thoughtful strategies for supporting people across the lifespan. These approaches should recognize that smart investments in people of one generation reap benefits for those in other generations in the form of a stronger workforce and quality of life and well-being. The administration must reverse harmful and discriminatory actions that have targeted individuals on the basis of their sexual orientation or race and move quickly to address structural issues that are disproportionately harming children, youth and older adults of color.
Generations United is a national organization dedicated to advancing policies and programs that promote connections across generations and mutually benefit older and younger people. We are home to the National Center on Grandfamilies- a leading voice for families where grandparents, other relatives and close family friends are raising children whose parents cannot. This memo outlines our recommendations for administrative action to promote intergenerational strategies to help all generations, with special attention to grandfamilies.
Recommendations to Promote Intergenerational Connections and Programs
Investing in intergenerational connections and programs is key to building back better. People in communities should not live segregated into age-graded silos. All generations live and work together daily. As people live longer, families and households are often comprised of multiple generations. To support people at all ages and stages of life, our policies should not be siloed by age. A 2018 Generations United survey of adults in the U.S. found that 88% wanted the federal government to invest in the wellbeing of both children and elders and 78% believed that the federal government should invest in programs that bring together young and old Americans. Adopting an intergenerational solutions approach to governing and serving our nation’s communities will save money and expand resources while improving the lives of people of all ages. Committing to making intergenerational wellbeing a focus of the administration will help address many problems we are facing.
We urge the Biden Administration to prioritize and promote intergenerational programs and connection by doing the following:
Promote Intergenerational Shared Sites, which are settings where children, youth and older adults participate in services or programs concurrently at the same site or on the same campus. Shared sites offer opportunities for people of multiple generations to share resources and interact regularly. These programs can take many forms such as a child care center in a senior care home or an adult day program. While regulatory challenges and generational siloes have prevented these from being commonplace in our society, they can provide care facilities with diversified revenue streams and lead to better outcomes for all generations. Older adults gain a sense of purpose and well-being, which is associated with improved overall health, while children’s social and emotional skills accelerate.
The Biden administration’s current plan includes child care tax credits for building child care centers and co-locating them at places of employment. This should be broadened to include intergenerational shared sites. The Administration should encourage the creation of new shared sites and commission a study identifying where they are located and key characteristics of programs for the purpose of developing a shared site database.
Offer incentives for programs that serve different generations to collaborate with one another and raise awareness about funding opportunities that already exist to develop and/or sustain intergenerational programs.
Hold Department of Health and Human Services (HHS) multi-department trainings on intergenerational programs and have a point person on these programs within each of the eleven operational divisions of HHS.
Make national service a core civic value. Programs like AmeriCorps and AmeriCorps Seniors (formerly SeniorCorps) already have bipartisan support, but are underfunded and underpromoted. These programs offer critical opportunities for people of all ages to be engaged as assets to their communities while gaining skills and feeling valued.
Support caregivers across generations. The recent reauthorization of the Older Americans Act includes intergenerational provisions that lay the ground work for a more robust national response to supporting the varied types of family caregivers nationwide. We urge the administration to pursue opportunities to financially support family caregivers who have given up income to provide care, including the Social Security and tax credits laid out in the Biden plan. Generations United has detailed below a set of recommendations to support an often-overlooked group of family caregivers, grandparents and other relatives raising children.
Recommendations for Administrative Action for the Department of Health and Human Services to Support Grandfamilies/Kinship Families:
About 2.7 million children are raised by relatives without their parents in the home. By stepping up to care for these children and keep them out of foster care, kin caregivers keep children with families and save taxpayers more than four billion dollars each year. Decades of research shows that these grandfamilies (also known as kinship families) have many strengths, but they also face many challenges, including difficulty accessing services and supports. Unlike parents, kin caregivers do not have an automatic legal relationship to the children and did not plan to raise these children, who typically come to them from traumatic situations. The COVID-19 pandemic is both heightening the challenges of existing grandfamilies and creating new grandfamilies.
We urge the Biden Administration to support grandfamilies through the following actions:
Promote Authentic Engagement of Grandfamily Voices. Create an advisory board and process for regular listening sessions with members of grandfamilies, including those raising children inside and outside the child welfare system. Engaging the voices of caregivers and young people with lived experience in grandfamilies is critical to ensuring that effective policy and practice reach those who need it. Generations United’s GRAND Voices network of more than 70 grandfamily caregivers representing 45 states and 11 tribes are available as a resource. View GRAND Voices at https://www.gu.org/explore-our-topics/grandfamilies/grand-network/
COVID Relief and Prioritization of Vaccinations for Grandfamilies:
- Prioritize caregivers in grandfamilies for COVID- 19 vaccinations. Caregivers in grandfamilies are often older and/or have underlying health conditions placing them at greater risk of extreme illness or death if they are exposed to COVID-19. A 2020 survey revealed that nearly a third of grandfamilies have no caregiving plan for their children if the caregivers die.
- Use language that explicitly includes grandfamilies/kinship families in COVID relief. COVID relief actions aimed at parents and their children should specifically call out grandfamily caregivers and the children they raise. Grandfamily caregivers typically do not see themselves in the word “parent” and state, tribal, and local governments and providers need this explicit clarity.
- Rapidly provide guidance and responses to questions from states, tribes and territories to help facilitate immediate access to new federal supports for kinship navigators and prevention services available in the Consolidated Appropriations Act of 2021 including those under Division X, Section 8 of the Supporting Foster Youth and Families Through the Pandemic Act.
Racial Equity and Non-Discrimination:
- Do not allow contracts to support providers who discriminate against children and families based on religion, marital status, sexual orientation, or gender identity, race or ethnicity.
- Develop and implement a plan for addressing racial bias in child welfare and related systems and remove the executive order prohibiting training that teaches about systematic racism.
- Recognize that historic and current systemic racism has led Black, American Indian and Alaska Native children to be overrepresented in kinship foster care and in the many more kinship families outside the child welfare system. Systemic racism and the overrepresentation of children of color in grandfamilies may be a contributing factor to the lack of supports and services for all kinship families. Specific actions noted in this memo will better ensure that these families are equitably supported and do not lead to more systemic racial inequities.
Establish an independent, nonprofit-based National Grandfamilies Technical Assistance Center to provide expertise to programs and systems around the country, elevate effective strategies, facilitate learning across sectors and geographic areas, and help multiple systems coordinate their efforts to ensure the needs of grandfamilies are met during national emergencies. This center will bridge the divide between the many systems that impact grandfamilies and provide holistic technical assistance to jurisdictions around the country seeking to improve supports for grandfamilies. According to the 2020 GAO report, “HHS Could Enhance Support for Grandparents and Other Relative Caregivers,” states want help concerning programs and policies that are designed to support grandfamilies and are overseen by HHS.
Fund the authorized programs of national significance under the National Family Caregiver Support Program (NFCSP), and focus on outreach, training, and technical assistance to the aging system to serve relative caregivers who are age 55 and older and raising other’s children. For 20 years, the NFCSP has provided supportive services such as respite care, support groups, and counseling to older relative caregivers of children, in addition to family caregivers of older adults. These supports are more important than ever. However, according to the GAO, only 23 states used their 2016 NFCSP funds to serve older relative caregivers of children. State officials told the GAO that they would like more tools for how to use this program.
Support the Efforts of the federal Advisory Council to Support Grandparents Raising Grandchildren and Implement its Recommendations. Promote active engagement of key federal agencies, a diverse group of grandfamily caregivers, birth parents, people raised in grandfamilies, and grandfamilies professionals in the council activities. Support broad and effective dissemination of the Council’s resources and its report to Congress. Develop a plan for implementation of report recommendations, including continuing a working group of federal agencies to coordinate efforts to support grandfamilies across systems. More information about the council is at www.acl.gov/SGRG.
Withdraw Proposed Rule RIN 0991–AC24, Securing Updated and Necessary Statutory Evaluations Timely. The proposed rule would retroactively impose an expiration provision on most HHS regulations, and establish “assessment” and “review” procedures to determine which, if any, regulations should be retained or revised. The Regulations Rule would create tremendous administrative burden for HHS and would cause far reaching harm across a broad group of Department programs and regulated entities, such as Medicaid, child care, and Temporary Assistance for Needy Families (TANF), which impact grandfamilies and other vulnerable children, youth and older adults.
Kinship Navigator Programs and Family First Prevention Services Act (Family First Act) Implementation
- Support the Development and Sustained Use of Quality Kinship Navigator Programs:
- Encourage states and tribes to operate Kinship Navigators that provide support to grandfamilies outside the child welfare system by partnering with aging services, income support programs, housing organizations and community-based supports.
- Address unnecessary barriers to Kinship Navigator Programs meeting Family First Act evidence-based standards by requiring the Title IV-E Prevention Services Clearinghouse (Title IV-E Clearinghouse) to provide individual responses to questions from programs seeking clarity on the rigorous evidence-based standards; give examples of ways kinship navigator programs can ethically operate and evaluate programs and meet the evidence-based standards; clarify that only the “promising” evidence-based standard is required for Kinship Navigator Programs to qualify for Family First Act reimbursement, and that Kinship Navigator Programs do not need to be included in the Family First Act requirement that 50% of a jurisdiction’s prevention programs meet the “well-supported” standard.
- Provide ongoing technical assistance to Kinship Navigator Programs on evaluation and program planning.
- Ensure that prevention services approved by the Title IV-E Clearinghouse can be adapted to make them culturally appropriate without requiring a full and separate review by the Clearinghouse in order to qualify for Title IV-E reimbursement.
- Support full implementation of the Family First Act including the provisions impacting kinship families as described in this summary: https://www.gu.org/resources/family-first-prevention-services-act/
Keep Children with Family and Promote Financial Equity and Support for Kinship Families
Compared to children in foster care with non-relatives, children in the care of relatives have better outcomes and stability, however, grandfamilies often do not have access to adequate support. Access to supports and services for grandfamilies varies significantly by whether or not the children are involved with the formal child welfare system. The vast majority of children being raised by grandparents or other relatives are raised outside the formal foster care system, giving them access to fewer resources. The following lays out recommendations for both types of families.
Children in Grandfamilies that are Not Involved with the Child Welfare System
- Improve Access to and Adequacy of Temporary Assistance to Needy Families (TANF): As was provided under Aid to Families with Dependent Children, clear guidance is needed for TANF grants, whose primary purposes include keeping children in the home of relatives:
- Highlight how to claim the good cause exemption for assigning child support to the state.
- Make clear exceptions to time limits and work requirements for kinship caregivers who are caring for young children and/or are age 55 and older.
- Eliminate asset limits for kinship caregivers to qualify for TANF, as has been implemented by several states. Caregivers must be able to keep retirement savings.
- Provide clear directives that child-only TANF grants cannot test caregiver income, as three states currently do. These grants are intended for the child based on the income of the child.
- Elevate promising practices from around the country, including having separate TANF child-only applications, videos on how to complete those applications, and policies that help parents reunify with their children, such as concurrent benefits in Washington State.
- Encourage states to provide the same amount of TANF child-only support for any eligible child in the household. Currently, states only incrementally support each additional eligible child in the household. This practice, which is unlike what happens with foster care maintenance payments, is contrary to equitable support. It forces large sibling groups being raised by a kinship caregiver to enter foster care, so they can receive the financial support needed to keep the siblings together.
- Learn more about TANF and Grandfamilies
Children in grandfamilies involved with the child welfare system:
- Ensure Financial Equity for Kinship Foster Care Families: Issue guidance that requires a Title IV-E child welfare agency’s approval of a relative as a kinship provider for a child in the legal custody of the agency is the same as licensing a relative. This clarity will support the roughly 108,000 children who are in kinship foster care and do not receive foster care maintenance payments. With this guidance, they will be able to receive that monthly support and a pathway to permanence through the Guardianship Assistance Program (GAP). Many states have been avoiding equitable support of kinship families, and disproportionally Black and African American children and families, through this “approval” process. Title IV-E of the Social Security Act is written so that legislative action would not be required to provide this support.
- Provide Guidance on Family Foster Home Licensing: As an incremental step toward explicitly equating approval with licensing as stated in Title IV-E, build on the helpful December 29th Children’s Bureau Information Memorandum (ACYF-CB-IM-20-08) which highlights the use of waivers of non-safety licensing standards and take the following steps concerning foster home licensing:
- Amend the National Model of Family Foster Home Licensing Standards to include two areas omitted in the first Model that can be found in the NARA Model of Family Foster Home Licensing Standards, on which the National Model is based: (1) emergency/provisional licensing standards that allow for the immediate placing of children with kin and (2) the standards concerning the assessment of criminal background checks.
- Highlight that there are very few federal requirements for Title IV-E licensing, that states have the flexibility to waive non-safety standards for kin, and that training requirements should be tailored to kin.
- Require Title IV-E child welfare agencies to report back to HHS on family foster care licensing based on the amended National Model, as is consistent with long standing federal law to periodically review licensing standards consistent with a national model. Publicly share their reports.
- Highlight Effective Kinship Strategies for Child Welfare Agencies: Building on the Children’s Bureau Information Memorandum (ACYF-CB-IM-20-08) and consistent with the GAO recommendation in its July 2020 report “HHS Could Enhance Support for Grandparents and Other Relative Caregivers,” issue periodic guidance highlighting strategies jurisdictions can use within the bounds of current federal law to promote the placement of children with kin immediately upon removal. This could include emergency approval practices with financial support, tailored processes for assisting kin in becoming fully licensed, family finding and engagement strategies, therapeutic kinship foster care, and Guardianship Assistance and Adoption Assistance.
- Continue to Promote Engagement of Extended Family to Support Birth Parents: Build on the April 29, 2020 Information Memorandum ACYF-CB-IM-20-06 on Foster Care Support to Families to highlight ways jurisdictions can engage extended family members as support to birth parents.
- Support Jurisdictions in Taking and Implementing the Guardianship Assistance Program Option: Building on the Children’s Bureau Information Memorandum (ACYF-CB-IM-20-08), work with states and tribes that have not adopted the Guardianship Assistance Program (GAP) to help them implement it.
- Allow Title IV-E to be used to reimburse attorneys for kinship caregivers, as is now allowed for attorneys for children and birth parents.
Enhanced Data Collection to Inform and Improve Services
- Collect more data on grandfamilies who are not involved with the child welfare system, including their race data, to inform services and supports. Currently, only limited data exist. The U.S. Census Bureau collects data on grandparents who self-identify as responsible for grandchildren. Similar data are available for the grandchildren of grandparents who are responsible for them. Both data sets include broad racial and ethnic breakdowns, but do not include racial and ethnic breakdowns within categories such as poverty and disability. This information is critical to informing services and supports and identifying racial disparities. No racial or demographic data are publicly available for other relatives, such as aunts or uncles, or the children they raise.
- Collect additional data on children in foster care with relatives including the numbers of children who are diverted from the child welfare system; are in the legal custody of the child welfare system with unlicensed kin and receive no foster care maintenance payments; are reunited with their parents; and exit foster care to guardianship or adoption. The need for these data points is detailed on page 59 Generations United’s toolkit: African American Grandfamilies: Helping Children Thrive through Connection to Family and Culture.
- Work with Tribes to Better Understand Trends for American Indian and Alaska Native Children: To ensure proper implementation of the Indian Child Welfare Act (ICWA), develop a more detailed understanding of the trends in out-of-home placement and barriers to permanency for American Indian and Alaska Native children. A detailed description of the types of data are on page 61 of Generations United’s and National Indian Child Welfare Association’s toolkit: American Indian and Alaska Native Grandfamilies: Helping Children Thrive through Connection to Family and Cultural Identity.
- Urge states to analyze the racial data of grandfamilies both inside and outside the foster care system to inform an assessment and plan to address racial disparities.
Intergenerational Communities and Shared Site Resources
- Intergenerational Shared Sites Fact Sheet
- Federal Funding Opportunities for Intergenerational Shared Sites
- Intergenerational Shared Site Resource List
- The Best of Both Worlds: A Closer Look at Creating Spaces that Connect Young and Old
- I Need You, You Need Me: The Young, The Old, and What We Can Achieve Together (Report Infographic)
- All In Together: Creating Places Where Young and Old Thrive
- Child Welfare and Aging Programs: HHS Could Enhance Support for Grandparents and Other Relative Caregivers
- Facing a Pandemic: Grandfamilies Living Together During COVID-19 and Thriving Beyond
- Annual State of Grandfamilies Reports
- Grandfamilies Strengths and Challenges
- Grandfamilies.org—A national resource of state laws, legislation and information in support of grandfamilies within and outside of the child welfare system.
About Generations United:
For three decades, Generations United’s mission has been to improve the lives of children, youth and older adults through intergenerational collaboration, public policies and programs for the enduring benefit of all. We have been the catalyst for policies and practices stimulating cooperation and collaboration among generations, evoking the vibrancy, energy and sheer productivity that result when people of all ages come together. We believe that we can only be successful in the face of our complex future if generational diversity is regarded as a national asset and fully leveraged. www.gu.org
Generations United is home to the National Center on Grandfamilies, which is a leading voice for families headed by grandparents, other relatives and close family friends. Through the Center, Generations United leads an advisory group of organizations, caregivers and youth that sets the national agenda to advance public will in support of these families. Center staff conduct federal advocacy, provide technical assistance to state-level practitioners and advocates, and train grandfamilies to advocate for themselves. The Center raises awareness about the strengths and needs of the families through media outreach, weekly communications and awareness-raising events. It offers a broad range of guides, fact sheets and tools for grandfamilies, which cover issues from educational and health care access to financial and legal supports. These resources can be found at www.gu.org and www.grandfamilies.org.
Contacts: For more information or questions about this memo, contact the co-directors of Generations United’s National Center on Grandfamilies: Jaia Lent, firstname.lastname@example.org or Ana Beltran, email@example.com, 202-289-3979