BULLETIN FOR 

PROFESSIONALS

November 2013

What’s Inside:

• Child welfare and early 

intervention

• Promising strategies

• Funding strategies

• Resources

Addressing the Needs 

of Young Children 

in Child Welfare: 

Part C—Early 

Intervention Services

Enactment of the Part C referral provisions in the 

2003 reauthorization of the Child Abuse Prevention 

and Treatment Act (CAPTA) and in the Individuals 

with Disabilities Education Improvement Act of 2004 

(IDEA) opened the door to a powerful partnership 

with great potential benefits for children under age 

3 involved in substantiated cases of abuse or neglect 

and their families. For child welfare administrators, 

these provisions offer tools to enhance policy and 

practice and ensure compliance with Federal child 

welfare requirements that focus on child well-being. 

The provisions also connect child welfare staff to 

Child Welfare Information Gateway

Children’s Bureau/ACYF/ACF/HHS

1250 Maryland Avenue, SW

Eighth Floor

Washington, DC 20024

800.394.3366

Email: info@childwelfare.gov

https://www.childwelfare.gov
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early intervention service providers, which 

can help child welfare staff in assessment, 

service delivery, and permanency planning. 

This partnership can expand the array of 

supports and resources for children and their 

caregivers to promote safety, permanency, and 

well-being. 

This bulletin describes the intersection of 

child welfare and early intervention, provides 

an overview of Part C, highlights the benefits 

of Part C for child welfare, and outlines how 

child welfare professionals can support Part 

C efforts. It also describes implementation 

challenges and provides promising strategies 

for implementing Part C provisions, including 

examples from the field. 

 Child Welfare and Early

There is significant overlap in the population 

of young children with substantiated abuse 

or neglect and those who experience 

developmental delays. Federal legislation has 

recognized this through provisions for early 

intervention and requirements for child welfare 

professionals to refer potentially eligible 

children to early intervention programs for 

identification. 

Special Needs of Children in 

Child Welfare 

Research shows that children who are 

abused or neglected often experience 

physical, cognitive, emotional, behavioral, 

and social problems, including attachment 

disorders, cognitive delays, and altered brain 

development (Child Welfare Information 

Gateway, 2009). This risk is greatest for 

the very young. In 2011, 27.1 percent of 

maltreatment victims were ages birth to 3, 

with children younger than 1 year having 

the highest victimization rate (21.2 per 

1,000 children of the same age group) (U.S. 

Department of Health and Human Services, 

2012b). One-fifth (20 percent) of children 

in foster care are under the age of 3 (U.S. 

Department of Health and Human Services, 

2012a). A national study found that more 

than two-fifths (42.3 percent) of children 

ages 1 to 5 who were part of a maltreatment 

investigation had some developmental need 

that may have qualified them for services 

under Part C (Casanueva et al., 2012). 

Providing early services and intervention to 

support the healthy development of young 

children can have positive effects that last 

throughout childhood and into adulthood 

(Center on the Developing Child at Harvard 

University, 2010). These services can impact 

children in a variety of domains, including 

physical and mental health, language and 

communication, cognitive development, and 

social and emotional development (National 

Early Childhood Technical Assistance Center, 

2011).

Early Intervention Legislation 

In recognition of these risks and the benefits 

of early intervention, the Keeping Children 

and Families Safe Act of 2003 (P.L. 108-36), 

which reauthorized CAPTA, required States 

to develop “provisions and procedures for 

referral of a child under age 3 who is involved 

in a substantiated case of child abuse or 

neglect to early intervention services funded 

under Part C of the Individuals with Disabilities 

Education Improvement Act” (§ 106(b)(2)

This material may be freely reproduced and distributed. However, when doing so, please credit Child 

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(A)(xxi)). The 2004 reauthorization of IDEA 

contains language parallel to this.1

IDEA 2004 also details specific requirements 

for State early intervention programs (EIPs), 

which are administered by lead agencies in 

each State (including departments of health, 

developmental disability, social services, 

children and families, or education). The lead 

agencies apply annually for their Part C grant 

awards and must meet certain requirements 

to participate. The following are examples of 

State Part C requirements:

• Ensure that appropriate early intervention 

(EI) services will be available to all eligible 

infants and toddlers in the State, including 

those who are in foster care, in the custody 

of a public child welfare agency, or 

otherwise considered a ward of the State.

• Implement a comprehensive Child Find 

system to identify, locate, and evaluate 

children needing early intervention services 

and to raise public awareness about what 

EI services are available. The lead agency 

must coordinate Child Find activities with 

other programs, including child protection 

and foster care. (For more information 

about Child Find, visit http://www.

ectacenter.org/topics/earlyid/idoverview.

asp.)

1	 IDEA requires States seeking grants to include in their

applications “a description of the State policies and procedures

that require the referral for early intervention services ... of a

child under the age of 3 who -- (A) is involved in a substantiated

case of child abuse or neglect; or (B) is identified as affected by

illegal substance abuse, or withdrawal symptoms resulting from

prenatal drug exposure.” (20 U.S.C. § 637(a)(6)). CAPTA section

106 [42 U.S.C. 5106a], subsection (b)(2)(A)(xxi) discusses specific

elements that must be included in a State’s plan, including

“provisions and procedures for referral of a child under the age

of 3 who is involved in a substantiated case of child abuse or

neglect to early intervention services funded under part C of the

Individuals with Disabilities Education Act.” Subsection (b)(2)

(A)(iii) requires “the development of a plan of safe care for the

infant born and identified as being affected by illegal substance

abuse or withdrawal symptoms.”

• Establish a State Interagency Coordinating 

Council (ICC) to advise and assist the 

lead agency in implementing the Part C 

program. The ICCs include representatives 

from various State agencies, including the 

State child welfare agency responsible for 

foster care, and at least 20 percent of the 

members must be parents of children with 

disabilities. (For additional information 

about the ICCs, including State websites, 

visit the Early Childhood Technical 

Assistance Center website at http://

ectacenter.org/topics/intercoord/icc.asp.) 

To view the full version of IDEA and the final 

regulations, which were released in 2011, 

visit http://idea.ed.gov/part-c/downloads/

IDEA-Statute.pdf (statute) and http://idea.

ed.gov/part-c/downloads/IDEA-Regulations.

pdf (final regulations). To view nonregulatory 

guidance from the Department of Education 

about changes to Part C made in the final 

regulations, view http://osep-part-c.tadnet.

org/uploads/file_assets/attachments/12/

original_Final_Regulations-_Part_C-DOC-ALL.

pdf. 

In general, children ages 3 to 21 with 

disabilities can receive special education 

as outlined in Part B of IDEA. For more 

information about Part B, visit the U.S. 

Department of Education at http://idea.

ed.gov/ or the National Dissemination Center 

for Children with Disabilities at http://nichcy.

org/laws/idea/partb.
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In 2011, 336,519 children under age 3 in the 

United States (including Washington, DC, 

and Puerto Rico) received early intervention 

services under Part C (Technical Assistance 

and Dissemination Network, n.d.). This 

accounts for 2.8 percent of all children in 

the United States under age 3. The CAPTA 

Reauthorization Act of 2010 (P.L. 111-

320) specified that States must annually 

report the number of children under 3 

who are involved in a substantiated case 

of child maltreatment who were eligible to 

be referred to EIPs under Part C and the 

number of those children actually referred 

to early intervention services. Beginning in 

2014, States will provide these data as part 

of their National Child Abuse and Neglect 

Data System (NCANDS) submissions.

BY THE NUMBERS: PART C 

ELIGIBILITY AND SERVICE RECEIPT

Steps in the Early 

Intervention Process 

Although the exact process in each 

jurisdiction may vary depending on State 

policies, the following are the basic steps in 

the early intervention process, as outlined in 

Federal law (Küpper, 2012):

1. Referral: A child under the age of 3 is 

referred to Part C because of a possible 

developmental delay or disability. When 

a child is identified as being potentially 

eligible for Part C, a formal referral must 

be made as soon as possible but in no 

case more than 7 days after the child has 

been identified as potentially eligible. 

All children under age 3 who (a) are the 

subject of a substantiated case of abuse 

or neglect or (b) are identified as being 

directly affected by illegal substance 

abuse or withdrawal symptoms resulting 

from prenatal drug exposure must be 

referred to the EI program.

2. Eligibility determination: The activities 

in this step help determine whether a 

child should receive EI services. The lead 

agency has 45 days to make eligibility 

determinations and hold the initial 

Individualized Family Service Plan (IFSP) 

meeting (see next step for additional 

details on the IFSP). 

a. Prior to each screening, evaluation, 

or assessment, the lead agency must 

provide the child’s parents with written 

notification about the proposed activity, 

and the parents must provide written 

consent.

b. States have the option to screen a 

child to determine whether the child is 

suspected of having a developmental 

delay before conducting the evaluation. 

The screening is considered part of the 

45-day timeline for referral to the initial 

IFSP meeting.

c. The EI program conducts a timely, 

comprehensive, multidisciplinary 

evaluation and assessment of the 

child to determine eligibility for Part 

C services. If the child is eligible for 

services due to having a specified 

diagnosed physical or mental condition 

that will likely result in a developmental 

delay, an evaluation to determine 

eligibility is not necessary. However, 

an assessment of a child’s strengths 

and challenges in each developmental 

area and an assessment of a family’s 

resources, priorities, and concerns are 

still conducted. Each State has its own 
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definition of developmental delay. (See 

State Eligibility Definitions later in this 

section for additional information.)

d. If the evaluation determines that 

the child is eligible, the EI program 

conducts two assessments: (1) a 

multidisciplinary assessment to 

determine the child’s unique strengths 

and needs and which services may be 

appropriate and (2) a family-directed 

assessment that focuses on supports 

and services the family may require to 

meet the developmental needs of the 

child.

3. Initial IFSP: The IFSP is a written plan that 

sets functional outcomes for the child 

and family and describes the services 

that will be provided to the child and 

family. It is developed by the IFSP Team, 

which includes the parents, the service 

coordinator, individuals who conducted 

the evaluation and assessment, and 

persons who will be providing EI services, 

as well as other family members and a 

family advocate if requested by the parent.

4. Services: EI services are provided that 

meet the identified functional child 

outcomes and the family’s identified 

concerns and priorities. Examples of 

EI services include special instruction, 

family training, occupational or physical 

therapy, psychological services, and 

speech language pathology services. 

For a complete list and description of 

early intervention services, see the Part C 

regulations at http://www.gpo.gov/fdsys/

pkg/CFR-2012-title34-vol2/xml/CFR-2012-

title34-vol2-sec303-13.xml.

5. IFSP review and renewal: At least every 

6 months, the IFSP team reviews the plan 

to determine the degree of progress that 

has been made and whether any revisions 

are necessary. Additionally, the IFSP team 

must conduct an annual review to evaluate 

progress on the IFSP, discuss the results of 

any current evaluations and assessments, 

and revise the plans, as needed. (Not all 

States require an annual re-determination 

of eligibility.)

6. Transition plan: A transition plan must 

be included in the child’s IFSP not fewer 

than 90 days and, at the discretion of all 

parties, not more than 9 months before 

the child’s 3rd birthday. The transition 

plan outlines what services the child 

may receive after he or she turns 3.

7. Exit: The child exits EI services.

State practice varies in cases in which a child is 

deemed to be at risk for developmental delays 

but is not eligible for Part C services. Only 38 

percent of States indicated they have written 

policies about referrals to other community 

resources (Cooper & Vick, 2009). Of those 

States with written policies, more than threequarters (76 percent) refer ineligible children 

to Early Care and Education Programs. Other 

possible referrals include primary pediatric 

care providers, local health departments, help 

lines, parent groups, or some combination of 

resources.

State Eligibility Definitions 

Aside from eligible children needing to be 

under the age of 3, IDEA stipulates that 

children must have either a developmental 

delay or a diagnosed physical or mental 

condition that has a high probability of 

resulting in a developmental delay. (For a list 

of conditions, view the IDEA regulations at 
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http://www.gpo.gov/fdsys/pkg/CFR-2012-

title34-vol2/xml/CFR-2012-title34-vol2-

sec303-21.xml.) States are able to develop 

their own criteria for determining the presence 

of developmental delays and what physical 

or mental conditions qualify a child for 

eligibility. States also have the option to serve 

children under 3 years who would be at risk 

of experiencing a substantial developmental 

delay if early intervention services were not 

provided. This could include children who are 

at risk of experiencing developmental delays 

because of biological or environmental factors 

that can be identified, including a history of 

maltreatment. (For a more extensive list of 

factors, refer to the IDEA regulations at http://

www.gpo.gov/fdsys/pkg/CFR-2012-title34-

vol2/xml/CFR-2012-title34-vol2-sec303-5.xml.) 

To view a summary of State definitions, 

including links to State websites, visit 

http://nectac.org/~pdfs/topics/

earlyid/partc_elig_table.pdf. 

Benefits of Part C for Child Welfare 

Referrals to the EIP support a State’s capacity 

to enhance the safety, permanency, and wellbeing of children and their families in the 

following ways:

• Referral to the EIP enhances service 

availability and accessibility, enabling 

children to receive appropriate IFSP 

services to meet their identified needs and 

to support their families’ capacity to help 

their children grow and develop. 

• EI programs can assist States in providing 

family-centered services that safely maintain 

children in their own homes, prevent 

removals, promote reunification, and 

stabilize placements.

• CAPTA’s referral provisions help State 

child welfare administrators comply with 

Federal child welfare regulations to ensure 

that “families have enhanced capacity 

to provide for their children’s needs ... 

children receive appropriate services to 

meet their educational needs, and children 

receive adequate services to meet their 

physical and mental health needs” [45 CFR 

1355.34(b)(1)(iii)].

How Child Welfare Can Support 

Part C Efforts 

Child welfare workers can help ensure that 

the developmental needs of children who 

are abused and neglected are addressed by 

attending training on child development, 

referring children to the EIP, and working 

closely with EIP staff. An EIP service 

coordinator can then help families (and child 

welfare professionals) navigate the eligibility 

process, design an IFSP, and ensure needed 

services are provided.

The EIP also permits caregivers to consent to 

and participate in services that can help them 

enhance their child’s development.2

 The stress 

of caring for a child with a disability or delay 

can strain family resources and threaten family 

stability. Child welfare professionals can refer 

caregivers to an EI Program and, if eligible, 

identified services may help them manage the 

stress of parenting their children, encourage 

the recruitment and retention of foster and 

adoptive families, stabilize placements, and 

support reunification.

2	 Foster parents can be considered parents or serve as

surrogate parents under the EIP, and many States include foster

parents under the parent definition of the 2004 IDEA 20 U.S.C.

1401(23).
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Implementation Challenges

Despite their documented need and eligibility 

for EIP services, there is concern that children 

involved with the child welfare system and 

who may have developmental delays are 

underidentified and underenrolled in EI 

services (Rosenberg, Smith, & Levinson, 2007; 

Scarborough & McCrae, 2008). Challenges to 

serving this population include the following: 

• Children eligible for EI services may not 

have a consistent caregiver in their lives 

who can observe their development over 

time.

• It is difficult to understand the complexity 

of the early intervention system, Federal 

laws, and State policies and effectively 

navigate the system on a child’s behalf. 

• Child welfare professionals, foster parents, 

and court personnel who are responsible 

for the well-being of these children are not 

always trained to identify developmental 

needs of children in foster care and may 

have limited knowledge about Part C 

services. One study found that child welfare 

caseworkers were able to recognize less 

than one-fourth (23 percent) of children 

with developmental problems (Rosenberg 

et al., 2007).

• At every stage of the EIP beyond referral, 

Federal legislation under IDEA requires 

parental consent and participation. Yet, the 

parents of children who have substantiated 

reports of abuse and neglect are sometimes 

unavailable to provide consent for services.

• Nearly all (98 percent of) States responding 

to a Part C workforce survey reported 

shortages in personnel who provide Part C 

services, particularly in rural areas (Moherek 

Sopko, 2010).

• EIP professionals may be unfamiliar with 

child welfare policies and procedures, with 

strategies for engaging families who are 

involuntarily involved in a referral to child 

welfare services, or both (Barth et al., 2008). 

Promising Strategies

Many States have developed policies and 

procedures to implement the Part C referral provisions of CAPTA and IDEA more 

effectively. Additionally, many localities and 

individual provider agencies have developed 

initiatives to ensure that children who are 

abused and neglected are linked to the EIP. All 

of these strategies address existing barriers to 

identifying, evaluating, engaging, and serving 

maltreated children and their families. This 

section will describe many of these strategies 

and provide specific State and local examples.

Collaboration 

Successful Part C implementation requires 

extensive interagency collaboration, not 

just between child welfare and EIP staff but 

among all relevant agencies and stakeholders 

(Keller-Allen, 2007; Lucas, Hurth, & Kasprzak, 

2010). This includes Medicaid, mental health, 

public health, maternal and child health, 

developmental disabilities, Early Head Start/

Head Start, education, and the courts.

Collaborative efforts can help child welfare 

and EIP administrators do the following:

• Clarify and share information about each 

system’s procedures

• Identify and convene leaders to facilitate 

implementation of the referral provisions 

and ensure compliance with all Federal 
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and State laws and regulations (e.g., ASFA, 

CAPTA, IDEA)

• Identify and tap available funding streams

• Develop written interagency agreements 

that establish workable referral and 

information-sharing procedures and 

ongoing communication mechanisms

• Promote clearer understanding of staff roles 

in each agency

• Develop consistent guidelines for processes 

such as obtaining consent, conducting 

evaluations, and appointing surrogate 

parents

• Create opportunities for cross-disciplinary 

training 

At the practice level, collaboration between 

child welfare and the EIP staff can help:

• Spotlight the safety and well-being needs 

of individual children and families

• Integrate child welfare and early 

intervention service goals and services

• Ease child welfare workload burdens by 

engaging the EIP service coordinator as a 

partner

• Identify new resources for consultation and 

technical assistance

• Enhance training programs for child 

welfare, court, and EIP professionals

As demonstrated by the examples on the next 

several pages, comprehensive and creative 

collaborations between State child welfare and 

the EIP systems have overcome many of the 

barriers to identifying, referring, and serving 

abused and neglected young children under 

the EIP. 

In January 2013, the Connecticut Department 

of Developmental Services (DDS), the State’s 

Part C lead agency, and the Connecticut 

Department of Children and Families (DCF) 

signed a memorandum of understanding 

(MOU) describing each department’s roles 

and responsibilities in referring children 

who were victims of substantiated abuse or 

neglect to the early intervention program 

for developmental evaluations. The two 

departments had developed another MOU 

in 2005 in response to the 2003 CAPTA 

reauthorization. The 2005 MOU, however, was 

limited in scope, and DCF wanted to revamp 

how it served this population. The 2013 MOU 

increases DCF’s role in bringing children to the 

attention of DDS for evaluations to determine 

early intervention eligibility. Although CAPTA 

requires child welfare agencies to refer children 

with substantiated cases of maltreatment 

to Part C, this MOU also assigns DCF the 

responsibility of screening all children with 

whom it has contact. Soon after the MOU 

was signed, the State legislature passed a 

law requiring that DCF screen children twice 

per year, which exceeds the requirements of 

the MOU. DCF is still working on how to best 

implement the MOU in conjunction with that 

legislation.

The MOU is available at http://www.birth23.

org/files/iamous/mou-dcf.pdf.

CONNECTICUT: MEMORANDUM 

OF UNDERSTANDING

Identification and Referral

The 2004 reauthorization of IDEA requires 

States to develop a comprehensive Child 

Find system that ensures eligible children, 

including infants and toddlers in foster care 
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or those with substantiated abuse or neglect, 

are identified, located, and referred to the 

EIP. Child Find efforts usually include outreach 

to child protection and preventive services 

agencies, as well as to hospitals and clinics 

that are likely to see infants and toddlers 

who have been abused or neglected. In 

one national survey, 69 percent of States 

recommend using a screening tool, and of 

those States, the top two recommendations 

for screening tools are the Ages and Stages 

Questionnaire (ASQ) and the ASQ: SocialEmotional (ASQ:SE) (Cooper & Vick, 2009). 

The same survey also reported, however, that 

most States (56 percent) do not require a 

professional with social-emotional expertise 

to sit on the multidisciplinary team during 

the evaluation stage, which may affect the 

adequacy of the evaluation (Woods, Smith, & 

Cooper, 2010).

Any EI service, including State-initiated 

screening, must be performed by a qualified 

professional as defined under IDEA. Some 

States provide training for child welfare staff 

in screening for developmental issues. Other 

States have child welfare staff rely on EI staff, 

who have had extensive training to conduct 

these screens. 

Staff from Michigan’s early intervention system 

noticed that many infants and toddlers referred 

to Part C from the child welfare system were 

not being identified as having developmental 

delays, which is contrary to the research. So, 

Michigan’s ICC established a committee in 2006 

to review tools that could help identify delays. 

The committee recommended the Devereux 

Early Childhood Assessment for Infants and 

Toddlers (DECA-I/T), which can be completed 

by parents or caregivers. During the pilot, 

staff discovered that it helped identify social 

and emotional delays that were not otherwise 

being identified through the Infant-Toddler 

Developmental Assessment (IDA), which was 

the State’s primary identification tool. Of the 

331 children found eligible during the pilot 

(out of 445 evaluated), 137 were found eligible 

based on IDA scores alone, 135 were found 

eligible based on the combined IDA and 

DECA-I/T scores, and 39 were found eligible 

based on the DECA-I/T alone (Michigan State 

Interagency Coordinating Council Ad Hoc 

Committee, 2008). This indicated that the 

DECA-I/T helped to identify children who 

otherwise would not have been found eligible 

for early intervention services. The DECA-I/T is 

now regularly used in conjunction with the IDA.

To help train early intervention staff on the 

identification of children with developmental 

delays, the Michigan Department of 

Education, which is the State’s Part C lead 

agency, and the Michigan Department of 

Community Health funded a position to 

provide professional development for early 

childhood mental health and early intervention 

specialists. The joint training helps facilitate 

and enhance the working relationship between 

the two fields, align policies, and reduce 

duplication of services and assessments. 

For more information about the DECA-I/T, 

visit http://www.centerforresilientchildren.

org/infants/. 

MICHIGAN: ENHANCING 

IDENTIFICATION
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Parental Consent

Once referred to the EIP, children involved 

in substantiated cases of abuse and neglect 

often face barriers to obtaining an assessment 

for needed services. Parents of children who 

have substantiated reports of abuse and 

neglect may be unavailable to consent to EIP 

assessment and services. Parents also may be 

unwilling to participate, fearing intrusion by 

another State agency. EIP professionals may 

be unfamiliar with child welfare procedures 

or strategies for engaging parents who are 

involuntarily referred to the child welfare 

system. 

Potential strategies to address these 

challenges include:

• Involve court personnel. A parent’s 

approval to have a child evaluated for EI 

services may demonstrate to the court 

that the parent is willing and able to act 

in the child’s best interest. A discussion 

along these lines may be more effective 

if initiated by the parent’s lawyer or the 

child’s attorney or court-appointed special 

advocate (CASA). 

• Involve public health nurses. Some States 

and localities have successfully used 

public health nurses to work with families 

in certain circumstances, such as when a 

family is reluctant to consent to a formal EIP 

multidisciplinary assessment. 

• Appoint surrogate parents. IDEA defines 

“parent” broadly to include biological and 

adoptive parents, a relative with whom the 

child is living, a legal guardian, and in some 

instances, a foster parent. It specifically 

precludes any State official from acting 

as a parent. IDEA also provides for the 

appointment of a surrogate parent if the 

child has no parent as defined under the 

Early Intervention law. Under IDEA, courts 

are authorized to order a surrogate parent 

to represent the child (§ 614(D)(iii)(II)(cc); § 

615 (b)(209A)(i)). The role of the surrogate 

parent is limited to representing the child in 

all matters related to the EIP. Nothing in the 

Federal law prohibits a foster parent from 

serving as the surrogate parent; however, 

States may have laws that limit foster 

parents serving as surrogates or otherwise 

acting as parents. 

Both the child welfare and EIP agencies have 

found that formal written agreements and 

easy-to-use forms that describe interagency 

policy and operations for seeking parental 

consent and appointing surrogate parents are 

helpful. 
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Workforce Improvement

To implement an effective EIP, States must 

ensure they have an adequate number of 

personnel and that those personnel are 

qualified to work effectively with young 

children and their families. Personnel should 

have an understanding of child development, 

Part C requirements, and best practices. States 

can use a multitude of approaches to develop 

and retain Part C personnel (Moherek Sopko, 

2010):

• Partner with school districts to share 

personnel

• Offer adequate compensation

• Fund loan forgiveness and stipend 

programs

• Collaborate with institutions of higher 

education to develop professional 

development programs

• Establish certificate programs focused on 

services for young children

• Develop online training modules

• Mentor

Cross-system training among State agencies, 

such as early education, child welfare, and the 

courts, can support workforce development 

by highlighting Federal, State, and agency 

requirements; the operation of other systems; 

and how the agencies can best work together. 

This can help ensure that all stakeholders 

share the same knowledge and understand 

one another’s language and also assist in 

identifying and addressing systemic barriers to 

accessing EIP services. 

The Family Networks Project in South 

Carolina, which is led by South Carolina First 

Steps to School Readiness and funded by 

the Quality Improvement Center on Early 

Childhood (QIC-EC), is conducting two 

studies on strategies to improve outcomes 

for children with developmental disabilities. 

The first study is examining whether families 

experience improved outcomes when they 

receive Part C services in conjunction with the 

Stepping Stones Triple P-Positive Parenting 

Program (SSTP) rather than Part C services as 

usual. SSTP is delivered in family homes by 

trained and accredited parent educators and 

typically includes 10 in-home sessions. The 

program helps parents set goals and apply 

strategies to affect issues and behaviors that 

are important to them. Forty-nine families 

were enrolled in this study. 

The second study is assessing the training 

of Part C service coordinators using the 

Preventing Child Abuse and Neglect: ParentProvider Partnerships in Child Care curriculum 

(PCAN). PCAN is intended to help these 

staff better understand the impact of child 

maltreatment and enhance relationships with 

parents. The project is studying whether 

family outcomes are improved when families 

receive SSTP services and IDEA Part C services 

enhanced by PCAN training as opposed 

to when they receive only SSTP services 

enhanced by PCAN training. Seventy-three 

service coordinators received the training, and 

41 families were enrolled to receive services. 

Final analyses of the data from both studies 

are underway as of August 2013.

For more information about this project, visit 

the QIC-EC website at http://www.qic-ec.org/

projects/columbia. 

SOUTH CAROLINA: STUDYING 

ENHANCED STRATEGIES
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In 2010, the County of Los Angeles 

Department of Mental Health received a 

6-year grant from the Substance Abuse and 

Mental Health Services Administration of 

the U.S. Department of Health and Human 

Services for Project ABC. The project 

also involves the County of Los Angeles 

Department of Children and Family Services, 

the Children’s Institute, Inc., For The Child, 

and Pacific Asian Counseling Services. 

One component of Project ABC is training 

mental health practitioners and other related 

professionals on evidence-based approaches. 

As the project tried to increase training 

attendance and promote the value of the 

training to other disciplines, staff recognized 

that the local Part C and child welfare 

agencies had excellent training facilities. 

They saw an opportunity to reduce training 

costs and forge additional partnerships. The 

project established an agreement with these 

agencies that allowed the project to use the 

training facilities in exchange for a certain 

number of training slots for agency staff. 

Project ABC staff also reached out to partner 

organizations to determine which topics would 

be of interest and, in one case, collaboratively 

developed the training with them. The four 

trainings conducted thus far have covered 

observing children’s behavior, cultural issues, 

early childhood assessments, and infant 

mental health, and 323 professionals from the 

early intervention, child welfare, medical, and 

juvenile justice fields have attended.

For more information about Project ABC, 

visit http://www.projectabc-la.org/.

LOS ANGELES: COLLABORATIVE 

TRAINING 

Tracking and Oversight 

Referral alone will not necessarily ensure 

enrollment and services. Several States have 

developed policies and programs to track 

both individual children and aggregate case 

data. These data can inform programmatic 

and policy decisions and help monitor 

programs and ensure the accountability crucial 

to high-performing EIPs (Lucas et al., 2010). 

Some States use the courts to help ensure 

referral to and enrollment in the EIP (Dicker & 

Gordon, 2006). Under Federal child welfare 

laws, every child in foster care has court 

hearings to review case status and assess 

permanency goals. These hearings present 

opportunities to inquire into the well-being of 

young children.

States also can develop formal mechanisms 

or policies to share information with decisionmakers responsible for advocating on 

behalf of abused and neglected children, 

including judges, attorneys for children and 

parents, guardians ad litem, and CASAs. 

Courts have the opportunity to inquire as to 

whether infants and toddlers are referred to 

and enrolled in the EIP and ensure relevant 

information is shared. 

 
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Funding Strategies

EI funds typically cover the costs of 

administration, evaluation, and service 

coordination. However, lead agencies in each 

State determine how services for eligible 

children will be funded. States use a wide 

variety of Federal, State, and local funding 

sources to fund their EIPs, with States using 

an average of eight different sources to fund 

their programs (IDEA Infant and Toddler 

Coordinators Association, 2012a). Medicaid 

and Part C are the primary Federal funding 

sources, with States also using their own 

general funds, State Medicaid, State Part C, 

and private insurance. Even with the multitude 

of funding sources, however, 39 percent of 

States responding to a finance survey reported 

they were facing a deficit for the program 

in fiscal year 2012. As a result of State fiscal 

issues, six States reported narrowing eligibility 

for EIs during the past year, and 11 States 

made eligibility criteria more restrictive during 

the past 3 years (IDEA Infant and Toddler 

Coordinators Association, 2012b).

Medicaid 

Medicaid’s Early and Periodic Screening, 

Diagnosis and Treatment Program (EPSDT) 

reimbursement can be used to maximize State 

resources for early intervention services. The 

EPSDT program is a health-care program 

for Medicaid-eligible children ages birth to 

21. It is designed to detect and treat health 

problems early through regular medical, 

dental, vision, and developmental screenings. 

Many children who have experienced 

maltreatment and nearly all children in outProject PLAY (Positive Learning for Arkansas’ 

Youngest) is an early childhood mental health 

consultation program that seeks to promote 

positive social and emotional development 

and decrease problematic social and emotional 

behaviors in early child care settings. It is 

administered by the University of Arkansas 

for Medical Sciences and funded by the 

Arkansas Department of Human Services 

Division of Child Care and Early Childhood 

Education. Project PLAY does not conduct the 

initial screenings or assessments for children 

with possible developmental delays, but its 

mental health consultants help child care 

providers learn to access the information from 

those assessments and suggest strategies to 

support the developmental needs of these 

children. The mental health consultants also 

help teachers learn to identify children who 

were not initially deemed Part C-eligible 

but who may be eligible due to emerging 

or undetected delays. Additionally, the 

project teaches child care providers how to 

become part of the child welfare team, which 

may include attending meetings or sharing 

information about the needs of children in 

foster care who are in early child care settings.

For more information about Project PLAY, 

visit http://familymedicine.uams.edu/

research-and-scholarly-activity-continuingmedical-education-cme/community-researchfamily-and-preventive-medicine/projects/

projectplay/. 

ARKANSAS: EARLY CHILDHOOD 

MENTAL HEALTH CONSULTATION
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of-home care will meet income eligibility 

guidelines for Medicaid.3

EPSDT permits States to use Medicaid 

to finance an array of services that might 

otherwise be ineligible for Medicaid 

reimbursement, including early intervention 

services and developmental screening (see 

42 U.S.C. 1396d(a)). These services must 

be listed in the Medicaid State plan. States 

should consult with the Centers for Medicare 

and Medicaid Services (CMS) of the U.S. 

Department of Health and Human Services to 

determine the extent to which EIP services, 

such as the ones listed below, may be billable 

to Medicaid:

• Assessment of the child and the child’s 

home life 

• Physical, occupational, and speech therapy 

• Vision and hearing testing, diagnosis, and 

treatment, such as eyeglasses and hearing 

aids

• Nutritional assessment and intervention

• Basic living and social skills development

• Parent skills training

• Case management

• Home visiting programs, including visits by 

public health nurses to provide screening 

and referral of children to the EIP

• Transportation costs for the child to 

receive services, as well as the cost of an 

attendant to accompany the child where 

the attendant is not a family member 

Other Federal Funds

Some State agencies use other Federal 

funds and programs to support EIP referral, 

evaluation, and services for abused 

and neglected children, as well as child 

development training for professionals. 

States have found it helpful to seek additional 

guidance from the funding source regarding 

allowable activities. 

• Maternal and Child Health Program 

(MCH) (title V of the Social Security Act). 

MCH provides a health-services safety 

net for women and children to ensure 

basic health care; it can be used for 

screening, assessments, and follow-up 

medical care. States also can use these 

funds for special projects of regional and 

national significance, including training for 

professional staff. 

• Head Start/Early Head Start. Head 

Start requires grantees to perform or 

obtain developmental screenings and 

arrange or obtain further diagnostic 

testing, examination, and treatment for 

children with a suspected disability or 

developmental delay. It also requires 

grantees to establish partnerships with Part 

C and child protective services.

• CAPTA. The Basic State Grant program 

under CAPTA requires States to develop 

a process to ensure the referral of eligible 

children for early intervention services. This 

grant funding may be used to fulfill this 

requirement. 

• Temporary Assistance for Needy Families 

(TANF). Many States have used TANF to 

fund preventive programs that reduce outof-home placement, including assessment, 

case management, and family instruction 

(Dicker, Gordon, & Knitzer, 2001).

3	 Children eligible for title IV-E are categorically eligible for

Medicaid (i.e., they are automatically eligible). States have the

option of providing Medicaid coverage for children who receive

State-funded foster care (McCartney, 2010).
Addressing the Needs of Young Children in Child Welfare: Part C—Early Intervention Services https://www.childwelfare.gov

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Welfare Information Gateway. Available online at https://www.childwelfare.gov/pubs/partc.cfm

Additional funding streams include title 

IV-B child welfare services program and IV-B 

Subpart 2 funds under the Promoting Safe and 

Stable Families program, Abandoned Infant 

Assistance Act funds, and funding streams 

that support substance abuse treatment and 

jail diversion programs. Additionally, multiple 

funding streams may be used to support a 

particular program, such as home visiting. 

For example, in some communities, home 

visiting, which can be an effective means to 

identify eligible children and provide services, 

is funded through Maternal, Infant, and Early 

Childhood Home Visiting grants, TANF, and 

the Child Care and Development Block Grant, 

as well as Part C (Johnson-Staub & Schmit, 

2012).

Conclusion

The Part C referral provisions of IDEA 

support access to early intervention services 

for children who have experienced abuse 

or neglect. The strategies discussed in this 

bulletin may help States consider options 

for fully implementing the CAPTA and 

IDEA directives. By providing access to 

early intervention services, child welfare 

administrators can better promote the healthy 

development of vulnerable children and their 

families.

Additional Resources

Child Welfare 360° (Spring 2013). Explores 

issues related to children with disabilities in 

child welfare. http://www.cehd.umn.edu/

ssw/cascw/attributes/PDF/publications/

CW360_2013-05.pdf

Child Welfare Information Gateway. Provides 

information on a wide range of child welfare 

issues, including Part C of IDEA. https://www.

childwelfare.gov/systemwide/service_array/

earlychildhood/childwelfare.cfm 

IDEA Infant & Toddler Coordinators 

Association. Promotes mutual assistance, 

cooperation, and the exchange of information 

and ideas in the administration of Part C and 

to provide support to State and territory Part 

C coordinators. http://www.ideainfanttoddler.

org/ 

Learn the Signs. Act Early. Provides 

information about an initiative of the U.S. 

Department of Health and Human Services, 

Centers for Disease Control and Prevention 

to improve early identification of children with 

developmental disabilities. http://www.cdc.

gov/ncbddd/actearly/index.html

National Dissemination Center for Children 

with Disabilities. Provides information on 

disabilities in children and youth, programs 

and services, IDEA, and research-based 

effective practices, including Building the 

Legacy for Our Youngest Children with 

Disabilities: A Training Curriculum on Part C of 

IDEA 2004 (http://nichcy.org/laws/idea/legacy/

partc). http://nichcy.org/ 

National Early Childhood Technical 

Assistance Center (NECTAC). Supports 

the implementation of the early childhood 

provisions of the Individuals with Disabilities 

Education Improvement Act (IDEA). http://

ectacenter.org/

Project Forum. Includes more than 100 

documents on various special education 

policy issues. http://www.nasdse.org/Projects/

ProjectForum/tabid/415/Default.aspx
Addressing the Needs of Young Children in Child Welfare: Part C—Early Intervention Services https://www.childwelfare.gov

16 This material may be freely reproduced and distributed. However, when doing so, please credit Child 

Welfare Information Gateway. Available online at https://www.childwelfare.gov/pubs/partc.cfm

State Part C Coordinators. Lists contact 

information for the State Part C coordinators 

and the website for State early intervention or 

Part C websites. http://ectacenter.org/contact/

ptccoord.asp 

Tracking, Referral and Assessment Center 

for Excellence (TRACE). Helps identify 

and promote the use of evidence-based 

practices and models for improving child find, 

referral, early identification, and eligibility 

determination for young children with 

developmental delays or disabilities. http://

www.tracecenter.info/

U.S. Department of Education, Office 

of Special Education Programs. Provides 

resources related to IDEA and its 

implementing regulations. http://idea.ed.gov/

explore/home 

References

Barth, R. P., Scarborough, A. A., Lloyd, E. 

C., Losby, J. L., Casanueva, C., & Mann, 

T. (2008). Developmental status and early 

intervention service needs of maltreated 

children: Final report. Retrieved from http://

aspe.hhs.gov/hsp/08/devneeds/report.pdf

Casanueva, C., Wilson, E., Smith, K., 

Dolan, M., Ringeisen, H., & Horne, B. 

(2012). NSCAW II wave 2 report: Child 

well-being. Retrieved from http://www.

acf.hhs.gov/programs/opre/resource/

nscaw-ii-wave-2-report-child-well-being

Center on the Developing Child at 

Harvard University. (2010). The 

foundations of lifelong health are built 

in early childhood. Retrieved from 

http://developingchild.harvard.edu/

resources/reports_and_working_papers/

foundations-of-lifelong-health/

Child Welfare Information Gateway. (2009). 

Understanding the effects of maltreatment 

on brain development. Retrieved from 

https://www.childwelfare.gov/pubs/issue_

briefs/brain_development/effects.cfm

Cooper, J. L., & Vick, J. (2009). Promoting 

social-emotional wellbeing in early 

intervention services: A fifty-state view.

Retrieved from http://www.nccp.org/

publications/pdf/text_885.pdf

Dicker, S., & Gordon, E. (2006). Critical 

connections for children who are abused 

and neglected: Harnessing the new Federal 

referral provisions for early intervention. 

Infants & Young Children, 19, 170–178. 

Retrieved from http://www.hunter.

cuny.edu/socwork/nrcfcpp/downloads/

teleconferences/Critical_Connections.pdf

Dicker, S., Gordon, E., & Knitzer, J. (2001). 

Improving the odds for the healthy 

development of young children in foster 

care. New York: National Center for 

Children in Poverty.

IDEA Infant and Toddler Coordinators 

Association. (2012a). ITCA Finance 

Survey. Retrieved from http://www.

ideainfanttoddler.org/pdf/2012-FinanceSurvey-Report.pdf
Addressing the Needs of Young Children in Child Welfare: Part C—Early Intervention Services https://www.childwelfare.gov

17 This material may be freely reproduced and distributed. However, when doing so, please credit Child 

Welfare Information Gateway. Available online at https://www.childwelfare.gov/pubs/partc.cfm

IDEA Infant and Toddler Coordinators 

Association. (2012b). 2012 ITCA Tipping 

Points Survey: Part C implementation: State 

challenges and responses. Retrieved from 

http://www.ideainfanttoddler.org/pdf/2012-

ITCA-State-Challenges-Report.pdf

Johnson-Staub, C., & Schmit, S. (2012). Home 

away from home: A toolkit for planning 

home visiting partnerships with family, 

friend, and neighbor caregivers. Retrieved 

from http://www.clasp.org/admin/site/

publications/files/Home-Away-from-Home.

pdf

Keller-Allen, C. (2007). Implications of 

the CAPTA requirement for referrals 

from child welfare to Part C. Retrieved 

from http://www.nasdse.org/

DesktopModules/DNNspot-Store/

ProductFiles/150_16cd156e-3e62-4264-

a3b2-6d06815e78a2.pdf

Küpper, L. (Ed.). (2012). The basics of early 

intervention (Module 1): Section 1 – The 8 

basic steps of early intervention. Retrieved 

from http://nichcy.org/laws/idea/legacy/

partc/module1

Lucas, A., Hurth, J., & Kasprzak, C. (2010). 

Essential elements of high performing, high 

quality Part C systems. NECTAC Notes, 

25. Retrieved from http://www.nectac.

org/~pdfs/pubs/nnotes25.pdf

McCartney, S. (2010). Making Medicaid 

happen: Providing title XIX to title IV-E 

populations. PowerPoint. Retrieved from 

http://aaicama.org/cms/resources-docs/

MA_Eligibility_2010.pdf 

Michigan State Interagency Coordinating Council 

Ad Hoc Committee. (2008). Early On social 

emotional tools pilot final report. Retrieved 

from http://eotta.ccresa.org/Files/PDF/

EarlyOnSocialEmotionalToolsPilotFinalReport08.

pdf

Moherek Sopko, K. (2010). Workforce 

preparation to serve children who receive 

Part C services. Retrieved from http://nasdse.

org/DesktopModules/DNNspot-Store/

ProductFiles/86_7b9701c9-c1d3-4c85-a6b7-

e5756646664d.pdf

National Early Childhood Technical Assistance 

Center. (2011). The importance of early 

intervention for infants and toddlers with 

disabilities and their families. Retrieved 

from http://www.nectac.org/~pdfs/pubs/

importanceofearlyintervention.pdf

Rosenberg, S. A., Smith, E. G., & Levinson, A. 

(2007). Identifying young maltreated children 

with developmental delays. In R. Haskins, 

F. Wulczyn, & M. Bruce Webb (Eds.), Child 

protection: Using research to improve policy 

and practice (pp. 34–43). Washington, DC: 

Brookings Institution Press.

Scarborough, A. A., & McCrae, J. S. (2008). 

Maltreated infants: Reported eligibility for Part C 

and later school-age special education services.

Topics in Early Childhood Special Education, 

28(2), 75–89.

Technical Assistance and Dissemination Network. 

(n.d.). Part C Child Count: 2011. Retrieved 

from http://uploads.tadnet.org/centers/97/

assets/2414/download
Addressing the Needs of Young Children in Child Welfare: Part C—Early Intervention Services https://www.childwelfare.gov

U.S. Department of Health and Human Services, 

Children’s Bureau. (2012a). The AFCARS report: 

Preliminary FY 2011 estimates as of July 2012. 

Retrieved from http://www.acf.hhs.gov/sites/

default/files/cb/afcarsreport19.pdf

U.S. Department of Health and Human Services, 

Children’s Bureau. (2012b). Child Maltreatment 

2011. Retrieved from http://www.acf.hhs.gov/

programs/cb/resource/child-maltreatment-2011

Woods, T. A., Smith, S., & Cooper, J. L. (2010). 

Promoting the social-emotional wellbeing 

of infants and toddlers in early intervention 

programs: Promising practices in four 

communities. Retrieved from http://nccp.org/

publications/pdf/text_946.pdf

Suggested Citation: 

Child Welfare Information Gateway. (2013). 

Addressing the needs of young children 

in child welfare: Part C—Early intervention 

services. Washington, DC: U.S. Department 

of Health and Human Services.

Acknowledgment: This bulletin is an update 

of the 2007 Child Welfare Information 

Gateway publication of the same title that 

was developed in partnership with Sheryl 

Dicker, J.D., and Elysa Gordon, M.S.W., J.D. 

U.S. Department of Health and Human Services

Administration for Children and Families

Administration on Children, Youth and Families

Children’s Bureau