Runaway and Homeless Youth Act: Current Issues for Reauthorization
Released: 2015-10-07T00:00:00

Introduction

The Runaway and Homeless Youth program is the largest targeted federal program that provides assistance to youth under age 23 who are homeless or have run a way. The program was established by the Runaway Youth Act as Title III of the Juvenile Justice and Delinquency Prevention Act of 1974 (JJDPA; P.L. 93-415 ), and has since been amended nine times.

Amendments to the act in 1977 ( P.L. 95-115 ) renamed the act the Runaway and Homeless Youth Act, which was expanded to include homeless youth. The act was most recently authorized, from FY2009 through FY2013, by the Reconnecting Homeless Youth Act of 2008 ( P.L. 110-378 ). As currently enacted, the program includes three components: the Basic Center program (BCP), which provides short-term services for youth under age 18; the Transitional Living program (TLP), which provides housing and supports for youth ages 16 through 22; and the Street Outreach program (SOP)—referred to in statute as the Sexual Abuse Prevention program—which serves youth living on the streets who are unstably housed. FY2015 appropriations for the program totaled $114.1 million.

The House Committee on Education and the Workforce and the Senate Judiciary Committee have exercised jurisdiction over the RHY program. Legislation has been introduced in the 114 th Congress to reauthorize the Runaway and Homeless Youth Act. This report provides background on the federal response to runaway and homeless youth (RHY), including steps taken by federal agencies to end youth homelessness. Following this discussion is an overview of issues that may be relevant if Congress takes up reauthorization of the act. These issues are grouped as follows:

demographic and other data on runaway and homeless youth; effectiveness of programs that serve this population; efforts to connect RHY with their families; access to and funding for the program; supports for vulnerable RHY populations, including youth who are lesbian, gay, bisexual, transgendered, or questioning (LGBTQ); those who have been victims of sex trafficking or are at risk for sex trafficking; and those who have other risk factors; and interaction between the RHY system and child welfare and juvenile justice systems.

The Appendix provides an overview of accountability standards that have been drafted as part of a proposed rule for the Runaway and Homeless Youth program. The report is a companion to CRS Report RL33785, Runaway and Homeless Youth: Demographics and Programs , which provides detailed information about the program.

Background

Since at least the Great Depression, the federal government has responded to the needs of youth who were homeless or transient in some capacity. Depression-era programs for vulnerable youth focused on providing employment services, primarily through the Civilian Conservation Corps program; employment centers; and aid in the form of housing and basic provisions. Separately, the Social Security Act of 1935 (P.L. 74-231), as originally enacted, authorized indefinite funding for states to establish and expand services under the Child Welfare Services program "for the protection and care of homeless, dependent, and neglected children, and children in danger of becoming delinquent." This law and others addressed youth running away from home; however, they did not focus on providing services, or did so on a limited basis. The Runaway Youth Act, enacted in 1974, was the first law to authorize dedicated funding to runaway youth.

As currently enacted, the three programs under the Runaway and Homeless Youth program—the Basic Center program, Transitional Living program, and Street Outreach program—target distinct but overlapping populations and serve youth in different settings. Each of these programs competitively awards grants to nonprofit organizations.

The BCP is available to youth under age 18 and provides short-term shelter and other assistance to both youth and their families. BCP grants are awarded by a formula that distributes funding based on child population in each state and territory. The TLP provides assistance to youth ages 16 through 21 with longer-term residential and other services. The SOP engages runaway and homeless youth who live on or frequent the streets by providing counseling and referrals.

See Figure 1 for further detail. The Runaway and Homeless Youth program also supports a toll- free hotline so that runaways can learn about services in their communities; grants for services in rural communities; research and evaluations; and training and technical assistance. The program is administered by the Family and Youth Services Bureau (FYSB) in the U.S. Department of Health and Human Services' (HHS) Administration for Children and Families (ACF).

The Reconnecting Homeless Youth Act of 2008 ( P.L. 110-378 ) most recently reauthorized the Runway and Homeless Youth program through FY2013 (September 30, 2013). The law amended multiple provisions including those that address funding for the program, requirements for grantees that receive BCP and TLP grants, and accountability of programs and activities authorized under the Runaway and Homeless Youth Act. Notably, P.L. 110-378 required HHS to promulgate regulations that specify performance standards for public and nonprofit entities that receive BCP, TLP, and SOP grants. (See the Appendix for an overview of standards that have been proposed by HHS.) The law further required HHS to periodically submit to Congress an incidence and prevalence study of runaway and homeless youth, as well as the characteristics of a representative sample of these youth. HHS must consult with the U.S. Interagency Council on Homelessness (USICH) in developing the study. The law also directed the Government Accountability Office (GAO) to evaluate the process by which organizations apply for BCP, TLP, and SOP, including HHS's response to these applicants.

Federal Efforts to Address Preventing and Ending Youth Homelessness

Congress and the Obama Administration have taken steps in recent years to address preventing and ending youth homelessness. Two notable efforts include an HHS report to Congress on ending youth homelessness and a strategy put into place by the U.S. Interagency Council on Homelessness to end youth homelessness by 2020.

HHS Report to Congress

The 2003 reauthorization of the Runaway and Homeless Youth Act ( P.L. 93-415 ) required HHS, in consultation with USICH, to prepare a report to Congress on promising strategies to end youth homelessness. HHS submitted the report to Congress in 2007. It explained that there was little information in the research literature about the effectiveness of interventions for homeless youth, and that the few studies on interventions were not based on rigorous experimental or quasi- experimental research designs. For this reason, the report incorporated information about interventions in related fields for high-risk youth, including family interventions to prevent child abuse and neglect, interventions to reduce juvenile violence, and interventions that support successful transitions from juvenile detention and foster care. Based on these approaches, the report described the ways in which providers and others can intervene in the lives of homeless youth.

The report acknowledged that solutions to prevent and ameliorate youth homelessness will not be easily accomplished, and that no single approach exists to solve its problems; however, the report emphasizes that certain policy options may prevent and end youth homelessness. These options include (1) providing targeted education and support services to high-risk families with youth who may become homeless; (2) providing enhanced services to support youth as they transition from the juvenile justice and foster care systems because these youth are particularly vulnerable to becoming homeless; (3) providing a continuum of services, including "gateway" services for youth who are newly homeless to long-term supportive housing programs for youth who may not have the option to live with their families; and (4) helping to coordinate programs and services for youth who are homeless or are at-risk of becoming homeless. The report cites USICH as a coordinating body that can assist in these efforts. USICH and other federal agencies have since taken steps to address youth homelessness overall.

U.S. Interagency Council on Homelessness: Opening Doors

In addition to authorizing multiple programs to address homelessness, the 1987 Stewart B. McKinney Homeless Assistance Act ( P.L. 100-77 ) also established USICH. The HEARTH Act, enacted in 2009 as part of the Helping Families Save Their Homes Act ( P.L. 111-22 ), charged USICH with developing a National Strategic Plan to End Homelessness. In June 2010, USICH released this plan, entitled Opening Doors . The plan sets out four goals: (1) ending chronic homelessness by 2015; (2) preventing and ending homelessness among veterans by 2015; (3) preventing and ending homelessness for families, youth, and children by 2020; and (4) setting a path to ending all types of homelessness.

In September 2012, USICH amended Opening Doors to specifically address strategies for improving the educational outcomes for children and youth and assisting unaccompanied homeless youth. The strategies for preventing and ending youth homelessness include (1) obtaining more comprehensive information on the scope of youth homelessness; (2) building an evidence base of the most effective interventions for different subsets of youth; and (3) improving access to emergency assistance, housing, and supports for historically underserved groups of youth, including those with histories in the child welfare system, LGBTQ youth, pregnant or parenting youth, and youth with mental health needs.

In February 2013, an interagency working group to end youth homelessness developed a guiding document for ending youth homelessness by 2020. Known as the Framework to End Youth Homelessness , the document outlines a data strategy (to collect better data on the number and characteristics of youth experiencing homelessness) and a capacity strategy (to strengthen and coordinate the capacity of federal, state, and local systems to work toward ending youth homelessness). These strategies are outlined and discussed further in the following two sections. The framework specifies activities in each of these areas that can begin immediately, activities that will require new resources, and longer-term activities that build on earlier efforts and may require new resources and/or new legislative authority. Through these activities, USICH ultimately intends to improve outcomes for youth in four areas: stable housing, permanent connections, education or employment options, and socio-emotional well-being.

The remainder of this report discusses issues that may be relevant if Congress considers reauthorization of the Runaway and Homeless Youth Act. These issues include (1) estimates and demographic information on homeless and runaway youth; (2) program and youth outcomes; (3) funding for the Runaway and Homeless Youth program; and (4) serving vulnerable populations.

Estimates and Demographic Information on Runaway and Homeless Youth

This section provides background on federal efforts to estimate the number and characteristics of youth who are homeless and/or have runaway. As Congress considers reauthorization of the Runaway and Homeless program, it may wish to (1) determine if HHS's efforts (underway with USICH) are adequate in addressing the data reporting provisions that are specified in the Runaway and Homeless Youth Act; (2) determine whether the act provides adequate direction to HHS about its role in carrying out data collection efforts in coordination with the U.S. Department of Housing and Urban Development (HUD), which administers multiple programs for homeless individuals; and (3) the extent to which funding should be appropriated through new funding or by reallocating funds, such as through existing funding within the Runaway and Homeless Youth program, for the studies required by the law and/or new activities to improve data collection.

Background

Estimates of the number of youth who are homeless or runaways and their demographic characteristics are not necessarily straightforward. The accuracy of estimates depends on how counts take place, and may depend on the capacity of researchers and communities to conduct counts and use statistical sampling methods. Estimates also depend on which definitions of homelessness and runaway are used. Some research includes only selected runaway and homeless youth populations (homeless youth; runaway youth; or unaccompanied youth, which encompasses both runaway and homeless youth). Further, studies on the number and characteristics of runaway and homeless youth are dated.

Concerns over the lack of data are not new. For instance, testimony in the 110 th Congress suggested that a lack of data impairs policy making and that a comprehensive study is needed on estimates of runaway and homeless youth. Congress subsequently passed the Reconnecting Homeless Youth Act of 2008 ( P.L. 110-378 ), which, in part, addressed concerns about data on runaway and homeless youth. It added a new section to the Runaway and Homeless Youth Act that requires HHS, in consultation with USICH, to prepare a report to Congress that includes estimates of the incidence and prevalence of the runaway and homeless youth population ages 13 to 26. The act also directed HHS to assess the characteristics of these youth. In addition, HHS is required to conduct a survey of and direct interviews with a representative sample of homeless youth ages 13 to 26 to determine (1) past and current socioeconomic characteristics; (2) barriers to obtaining housing and other services; and (3) other information HHS determines useful, in consultation with states and other entities concerned with youth homelessness. The 2008 act does not specify the methodology for carrying out the studies, except to say that HHS should make the estimate based on the best quantitative and qualitative social science research methods available. The law specifically authorized such sums as may be necessary for the study for FY2009 through FY2013.

As mentioned, the USICH framework for ending youth homelessness includes a data strategy for collecting information about homeless youth specifically. This strategy has four components: (1) developing better strategies for counting youth in point-in-time (PIT) counts of homelessness; (2) coordinating federal data systems that collect information on youth experiencing homelessness and their receipt of services; (3) launching a national study on the prevalence and characteristics of youth homelessness; and (4) using this national study to make periodic estimates of youth homelessness over time. USICH has articulated that better data on youth homelessness can help social service agencies and other stakeholders advocate for the appropriate resources to support youth experiencing homelessness and allow social agencies to tailor resources to the specific needs of youth. These components are discussed in the following sections.

Point-in-Time Estimates

USICH and its federal partners are working with communities to develop better estimates of youth experiencing homelessness through what are known as point-in-time (PIT) counts. HUD requires Continuums of Care (CoC)—typically cities, counties, or combinations of both that organize and deliver housing and services for homeless individuals in each community—to collect information in each community on the number and characteristics of individuals and families experiencing homelessness on a single day in January (during the last 10 days) in at least every other year (odd calendar years). PIT counts differ from HUD's Homeless Management Information Systems (HMIS), which include data on homeless individuals collected by homeless service providers that receive HUD funding. These providers report the data to their local CoC and these data are used to derive national estimates of homelessness over a one-year period.

USICH and other federal agencies are increasingly using data from the PIT counts as a source to track trends and progress in eliminating homelessness. HUD requires communities to collect information on unaccompanied youth under age 18. This includes youth on their own, youth who are parents and their children, adolescent siblings, and other groups composed of only youth. Since 2013, HUD has required that PIT counts include unsheltered youth. Youth under age 25 who meet the definition of homeless under the McKinney-Vento Act (the major act that authorizes homelessness programs) are included in the count. This encompasses sheltered youth in runaway and homeless youth programs (including those that may not be funded under the federal program). Also since 2013, CoCs have been required to specifically identify the number of youth ages 18 or 18 to 24. Previously, these youth were included in a larger category of young adults ages 18 to 30. In addition, CoCs are required to count younger youth in a larger category of children under age 18.

PIT counts can capture information on youth who interact with RHY or other homeless service providers, as well as those who do not (i.e., sheltered and unsheltered youth). These counts do not provide a confident estimate of youth experiencing homelessness across the country. Counting sheltered and unsheltered unaccompanied youth is a challenge because they often do not use homeless residential services or develop relationships with local homeless services providers who can ensure that each youth is counted. Further, unsheltered youth may congregate in different places and at different times than other homeless individuals, and thus may not be brought to the attention of enumerators who conduct the PIT counts.

In response to these concerns, HUD has provided specific guidance on counting youth who are unsheltered. HUD recommends that CoCs coordinate with multiple entities—RHY service providers, homeless liaisons for local education agencies (i.e., school districts), and selected social service organizations—to assist with a comprehensive count of children and youth. HUD also encourages communities to recruit currently or formerly homeless youth to assist with the count, and to hold "magnet events" that include food and other appropriate incentives to draw in youth who typically do not use shelters and services. In addition, CoCs are encouraged to survey locations during multiple times throughout the day of the count and use social media to raise awareness and outreach. This guidance has been informed by an initiative, known as Youth Count!, to improve data collection on youth as part of PIT counts. With philanthropic support, USICH (and its partner agencies) provided technical assistance to nine communities to improve data collection on homeless youth as part of the 2013 PIT. The initiative was intended to aid the nine communities in developing and implementing strategies to reach unaccompanied youth experiencing homelessness and document lessons learned. The CoC agency was the lead entity for the Youth Count! in each of the nine communities. The agency partnered with other stakeholders, including homeless youth service providers, to implement the count.

The Runaway and Homeless Youth Act directs HHS, as appropriate, to consult with HUD to ensure coordination of programs and services for homeless youth. As Congress considers reauthorization of the act, it may want to determine the extent to which the act should specify the role of HHS and RHY grantees in participating in HUD's point-in-time counts.

Coordinating Existing Data Systems

HHS and HUD have taken steps to coordinate the data collection system for the Runaway and Homeless Youth program—known as NEO-RHYMIS (National Extranet Optimized Runaway and Homeless Youth Management Information System)—with HMIS. Until FY2015, data on youth served in the BCP and TLP, and the number of contacts made in the SOP, were collected from grantees via NEO-RHYMIS twice during the fiscal year. Specifically, the data system collected information on the basic demographics of the youth, the services they received, and the status of the youth (i.e., expected living situation, physical and mental health, and family dynamics, etc.) upon exiting the programs. RHY grantees are now required to report to HMIS. HMIS is a locally-administered data system used to record and analyze client, service, and housing data for individuals and families who are homeless or at risk of homelessness in a given community.

Service providers report the data to their local CoCs. HUD uses data from a sample of participating HMIS jurisdictions to derive a national-level estimate of the number of individuals who are homeless over a one-year period. This estimate is included in HUD's Annual Homelessness Assessment Report (AHAR), which provides Congress with detailed data on individuals and households experiencing homelessness across the country each year.

In April 2013, HUD issued a notice to change data elements within HMIS, including data on youth who have run away and/or are homeless. In May 2014, HUD and HHS (along with the Department of Veterans Affairs) released the 2014 HMIS Data Dictionary and 2014 HMIS Data Manual, which revise the HMIS data standards. These new standards went into effect on October 1, 2014. They are intended to provide guidance for HMIS vendors and administrators to collect HMIS data in a way that meets the data submissions requirements of each applicable federal program, including the Runaway and Homeless Youth program. The HMIS standards include the data collection questions that are in NEO-RHYMIS, along with new data elements. For example, new elements include information on income and sources of income (for TLP and RHY demonstration projects); health insurance status (all RHY programs); whether the youth has specified disabilities (all programs); whether the young person is at risk for or is a victim of commercial sexual exploitation (all RHY programs); whether family reunification was achieved (all RHY programs except SOP); information about the youth's employment status at entry and exit (all RHY programs except SOP); the types of programs to which the youth was referred (all programs); and the extent of transitional, exit, and aftercare plans for youth (all programs except SOP). It also specifies new categories for the issues identified by the youth and program staff (for BCP and TLP), and revises categories for types of referrals (for BCP and TLP) and whether youth completed the program (for all programs except SOP).

RHY grantees were required to begin reporting to HMIS by April 15, 2015. They must create an export file through HMIS, and submit the data to HHS twice each fiscal year. According to HHS, the department informed grantees about the initiative through a series of speaking engagements and workshops conducted at national homelessness conferences. HHS also conducted listening sessions in which grantees had the opportunity to provide feedback about the initiative. Also according to HHS, approximately half of Runaway and Homeless Youth program grantees that were surveyed by the department's technical assistance provider are HUD grantees, and therefore these grantees enter data on the youth they serve into both information systems. Merging the two systems may help to better assess the size and nature of homelessness among youth, while reducing the burden of Runaway and Homeless Youth grantees that input data into both systems.

The Runaway and Homeless Youth Act specifies that BCP and TLP providers are required to submit to HHS information about the number and characteristics of the youth they serve. As part of reauthorization of the act, Congress might consider whether the act should include additional direction on the participation of HHS and grantees in the new data collection process.

National Study on Prevalence of Youth Homelessness

The Federal Framework to End Youth Homelessness includes a strategy to design and implement a national study to estimate the number, needs, and characteristics of youth experiencing homelessness. The study is to include "coordinated approaches, such as building on an existing nationally-representative household survey and an enhanced national youth strategy for the HUD PIT count."

UISCH and its federal partners intend to estimate the prevalence and characteristics of youth experiencing homelessness over time, also pending available funds. These plans appear to be consistent with the requirements in the Runaway and Homeless Youth Act for a national incidence and prevalence study of youth. HHS has requested funds for the study as part of the budget request for FY2014 ($3 million), FY2015 ($2 million), and FY2016 ($2 million). HHS has also been developing a sampling methodology that will help inform the design of this study. No funds have been appropriated for this purpose. Legislation in the 114 th Congress ( S. 262 and S.Amdt. 290 and S.Amdt. 1127 to S. 178 ) would authorize $2 million for the study for each of FY2016 through FY2020 (the current authorization is such sums as necessary).

The National Network for Youth (NN4Y), a nonprofit organization representing the interests of RHY providers, and its partners recommend requiring that the study collect specific additional data that are not already specified in the law. Such data could incorporate information on trafficking victimization; whether youth identify as LGBT; pregnancy and parenting; and current or past involvement in either or both the child welfare system and juvenile/criminal justice system. S. 262 includes similar requirements, except that it would not specify data collection on LGBT status. It would also require collection of data on youth beginning at age 12 rather than 13 as in current law. Further, the bill would require HHS to collect data on barriers to youth receiving mental health services and education and job training.

A separate data collection effort—Voices of Youth Count—is underway by researchers with Chapin Hall Center for Children at the University of Chicago and its partners. It seeks to capture the number of unaccompanied homeless and runaway youth ages 14 to 24 who are not living with a parent. The project involves a literature review; interviewing and surveying youth and those around them, examining the effectiveness of resources for this population; and conducting quantitative analysis to arrive at estimates.

Youth Connection with Their Families

Youth most often cite family conflict as the major reason for their homelessness or episodes of running away. A literature review of youth experiencing homelessness suggests that a youth's relationship with a step-parent, sexual activity, sexual orientation, pregnancy, school problems, and alcohol and drug use were strong predictors of family discord. Among youth in the Runaway and Homeless Youth program, most cite family dynamics as a major concern when exiting the program. In FY2014, over 27,000 (out of 32,000) youth exiting the BCP and approximately 2,000 (out of approximately 3,000) youth exiting the TLP cited this concern (it was the most frequently cited issue for BCP youth and the second most frequently cited issue for TLP youth). The 2007 HHS report to Congress on strategies to end youth homelessness emphasized the importance of family relationships. It said that "to address the risk factors that lead to youth leaving and staying away from their homes, intervention approaches must emphasize strategies to strengthen and support families. Families, whether immediate or extended, are resources for homeless youth and should be actively involved in adolescents' transition to independence and adulthood."

The Runaway and Homeless Youth Act specifies that the BCP is intended to provide services as an alternative to involving youth who are runaways and/or homeless in the child welfare system (and other specified systems). The act requires BCP grantees to develop "adequate plans for contacting the parents or other relatives of the youth and ensuring the safe return of the youth according to the best interests of the youth." In addition, BCP grantees are directed to provide "individual, family, and group counseling, as appropriate … and may include home-based services for families with youth at risk of separation from the family." Most (69%) of youth exiting the BCP in FY2014 return to their parents' house. In addition, 15% to 17% of youth served by BCP grantees receive preventive services that can include mediation and family and individual counseling. According to HHS, most of those young people remain at home and do not stay at the center.

The statute does not address family support and reunification for the TLP and SOP. This may be due to the relatively younger age of youth served in the BCP and their living situations upon exiting. The TLP provides longer-term support to youth ages 16 to 21. Fewer than one out of five (15%) of youth in FY2014 went on to live with their parent(s) upon exiting the program. The SOP provides services to youth who live on the street, and presumably many of these youth have limited or no contact with their parents (HHS does not collect information on these youth). The regulations to accompany the Runaway and Homeless Youth Act specify that all grantees should ensure they have "plans for meeting the best interests of the youth involving, when possible, both the youth and the family" and that such plans include contacts with family within 24 hours (and not more than 72 hours) after the youth's admission into the program. In addition, HHS's proposed regulations for the program emphasize the importance of permanent connections for young people in programs funded under the Runaway and Homeless Youth Act.

The extent to which all providers with Runaway and Homeless Youth Act funds, or even BCP- funded programs, provide family interventions has not been fully examined. According to the 2007 HHS report to Congress, "shelters that place a strong emphasis on stabilizing youth and reunification with families or other appropriate long-term placements are critical in preventing prolonged episodes of homelessness among this population. Providers report that younger youth and those experiencing their first episode of homelessness are more likely to reconcile with families, if early intervention is available." A 2007 report, developed for a federal symposium on homelessness, emphasized that more attention should be paid to prevention and intervention strategies that focus on youth. The report goes on to say that such strategies could involve improving communication, developing conflict resolution skills, and increasing understanding of adolescent development.

The National Alliance to End Homelessness, an organization that seeks to prevent and end homelessness, defines family intervention along a spectrum that involves strategies such as family reunification, family connection, family finding, and aftercare services. Examples of these strategies can include support groups for parents and parenting skills classes. Some interventions have been assessed, though not necessarily through rigorous evaluation or specifically for youth who have run away or are homeless. One such approach is multisystemic therapy (MST) in which families are provided with intensive, home-based services facilitated by a therapist who empowers parents to better manage their adolescent's behavior and also coordinates services and supports for the family. Randomized controlled trials have shown that MST can reduce antisocial behavior; however, again, these evaluations have not focused on the RHY population in particular. Another promising model—used by a runaway and homeless youth provider, Project Safe, in Washington—provides phone consultation, support groups or workshops, and a resource library to parents or caretakers. The goal is to prevent teen homelessness and promote healthier family functioning. Outcome data from these interventions showed a significant decrease in the parental perception of the youth needing to leave the home. Further, some intervention models focus on families separated because their teens identify as LGBT. These models draw on findings that seek to strengthen families by informing them of the negative impacts and risks that "rejecting" behaviors can have on their child.

Reauthorization of the Runaway and Homeless Youth Act may provide an opportunity to examine the role of youth connection to their families. For example, the National Network for Youth has suggested that the act could extend family intervention and reconnection services to TLP participants when safe and appropriate. Legislation introduced in the 114 th Congress ( H.R. 1779 , S. 262 , and S.Amdt. 290 to S. 178 ) would add that BCP providers may implement services for assessing family engagement in supporting the youth and reunifying them with their families, and providing services to family members or (if appropriate) individuals identified as family by the youth. In addition, it would require that TLP applicants agree to provide counseling to youth who are homeless and to encourage, if appropriate, counseling that involves parents, legal guardians, or individuals that the youth identifies as family.

Program and Youth Outcomes

This section first describes how HHS currently assesses whether grantees receiving Runaway and Homeless Youth program funds are meeting the needs of youth who have run away and/or are homeless, and how HHS determines whether the Runaway and Homeless Youth program is effective overall. It then discusses the research literature on interventions for this population and the potential role of the Runaway and Homeless Youth Act in testing interventions.

Current Evaluation of the Program

The Family and Youth Services Bureau (FYSB) evaluates each grantee through the Runaway and Homeless Youth Monitoring System. Staff from regional Administration for Children and Families (ACF) offices and other grant recipients (known as peer reviewers) conduct an onsite review of the program, which involves interviewing grantee staff, reviewing case files and other agency documents, and conducting entry and exit conferences. The monitoring team then prepares a written report that identifies the strengths of the program and areas that require corrective action. The protocols used to conduct the onsite review generally follow the BCP Performance Standards, and are adapted for the TLP and SOP. The performance standards relate to how well the needs of youth who have run away and/or are homeless and their families are being met, and not the outcomes of services provided. Nine of these standards address service components (e.g., outreach, individual intake process, and recreational programs, etc.) and six focus on administrative functions or activities (e.g., staffing and staff development, reporting, and individual client files, etc.). On April 14, 2014, HHS issued a notice of proposed rulemaking (NPRM) that seeks to implement new performance standards and other requirements for Runaway and Homeless Youth program grantees. These proposed performance standards are outlined in the Appendix . For example, BCP and TLP grantees would be required to maintain at 90% or higher the proportion of youth who exit to safe and appropriate settings.

Separately, BCP and TLP grantees collectively are expected to meet certain outcomes. This is distinct from the performance standards and onsite review for determining whether individual grantees are meeting the needs of youth and families. Through FY2014, grantees were required to report outcome data through the NEO-RHYMIS reporting system, which included multiple data elements. HHS used the NEO-RHYMIS data to calculate four outcome measures in particular for the entire program:

Maintain the proportion of youth who are prevented from running away as a result of BCP non-shelter, preventive services. The FY2014 target was 96% and the result was 97.7%. Increase the proportion of youth living in safe and appropriate settings after exiting TLP services. The FY2014 target was 86% and the result was 87.8%. Increase the percentage of youth who complete the TLP by graduating or who leave ahead of schedule based upon an opportunity. The FY2014 target was 60% and the result was 61.8%. Increase the percentage of TLP youth participants who are engaged in community service and service learning activities while in the program. The FY2014 target was 37.6% and the result was 36.7%.

Evaluation of Interventions Generally

As discussed in the 2007 HHS report to Congress and other research, multiple interventions have been developed to assist youth who have run away and/or are homeless, but they have not been evaluated to determine whether they are effective. Researchers have pointed out that closing this gap in research "will require methodologically sound studies that include control (or at least comparison) groups in experimental (or at least quasi-experimental) research designs." To this end, efforts are underway at HHS to learn more about the long-term outcomes of youth who are served by the TLP using a rigorous research design. HHS has contracted with Abt Associates, a policy research organization, to conduct an evaluation of the TLP at select grantee sites. The study seeks to describe the outcomes of youth who participate in the program and to isolate and describe promising practices and other factors that may contribute to their successes or challenges. The study is examining delivery approaches, youth demographics, socio-emotional wellness, and life experiences. The study also includes an impact evaluation, with youth randomly assigned to the treatment (i.e., entry into TLP) and control groups to determine whether the TLP leads to different impacts for enrolled youth than for those who did not enroll. The evaluation is expected to conclude in FY2017.

Separately, HHS and other federal agencies are moving ahead with disseminating an intervention model that draws on evidence-based tools and practices for assisting youth who are homeless. This model is the main component of the capacity building strategy that is part of USICH's Framework to End Youth Homelessness (outlined in Figure 2 ) .

The intervention model emphasizes that providers should use valid and reliable screening and assessment tools to understand each youth's strengths and needs. It also specifies that intervention strategies should be based on scientific evidence for improving outcomes, provide culturally appropriate supports that account for the specific characteristics and needs of the youth, and emphasize settings and relationships where young people can heal and thrive. The framework envisions using federal and other resources to put the intervention model into practice and evaluate which approaches are most effective. Federal agencies would then disseminate and scale-up screening and assessment tools and effective interventions.

Since the model was disseminated, FYSB has modified requirements for Runaway and Homeless Youth grantees to help ensure their efforts align with the model. For example, FYSB has begun to require that grantees use appropriate screening and assessment tools to determine whether young people entering programs have a history of trauma and other issues. In addition, organizations applying for funding under the Runaway and Homeless Youth program have recently been required to ensure that case planning takes into account the youth risk and protective factors and their goals. Further, FYSB has provided training and technical assistance on specific practices that have some effectiveness, and has enhanced efforts to monitor the performance of grantees.

The Runaway and Homeless Youth Act currently authorizes HHS to make grants to carry out research and evaluation, and requires that in making such grants, HHS gives priority to certain types of projects. One type of project appears to be most germane to examining effectiveness of a program—"providing programs, including innovative programs, that assist youth in obtaining and maintaining safe and stable housing, and which may include programs with supportive services that continue after the youth complete the remainder of the programs." The reauthorization process could involve examining the role of evaluations, such as whether the law should place greater emphasis on testing promising intervention models or whether HHS might provide technical assistance to individual grantees about conducting more rigorous evaluations of their programs. The reauthorization process might also involve examining the goals of the TLP in particular because of the program's outcomes. Notably, approximately one-third (35.3%) of youth completed the TLP in FY2014. The remaining two-thirds did not complete the program: 26.5% did not complete the program because of other opportunities, 15.3% did not complete the program and had no other plans, and 22.9% were expelled or involuntarily discharged from the program.

Access to Funding

A related issue that may be of interest to Congress is youth access to the Runaway and Homeless Youth Act programs. Estimates of youth who have run away or are homeless exceed 1 million, and the program provides services to just a fraction of these youth. In recent years, the BCP has served approximately 32,000 to 52,000 youth annually and the TLP has served 3,000 to 4,400 youth annually. In a January 2014 analysis, HHS provided estimates for the number of beds available at HHS-funded BCP and TLP grantees. The analysis estimated that in FY2012, there were an average of 10 beds per BCP grantee, for a total of 3,102 beds across all grantees; and that in FY2013, there were 11 beds per TLP grantee, for a total of 1,635 beds across all grantees. The estimated total number of beds for these two programs was 4,737. The number of youth served does not correlate with the number of beds, as youth in both programs generally stay less than three weeks (for the BCP) and less than six months (for the TLP).

Table 1 shows the number of youth who were turned away from the BCP and TLP due to a lack of bed space from FY2007 through FY2014. Overall, between 7,000 and 11,000 young people were turned away each year from the BCP and TLP—with the greatest number of youth turned away in FY2010. Data for the SOP are collected only on the number of contacts that organizations made with youth, and not the actual number of youth served.

Program Funding Over Time

Advocates assert that funding is needed for the Runaway and Homeless Youth program to meet the needs of this population. They have recommended that funding be increased to $300 million. Table 2 shows appropriation levels for the major components of the program from FY2011 through FY2015.

Figure 3 shows the amount of funding appropriated for each of FY2001 through FY2014 in nominal dollars and FY2014 dollars (real dollars). FY2014 is the most recent year for which the Current Price Index (CPI) is available to examine these trends. In real dollars, funding ranged from a high of about $110 million in FY2013 to a low of $114 million in FY2014.

Continuum of Care (CoC) Program Funding

On a related point, providers of services to youth who have run away or are experiencing homelessness may have limited access to funding from the major program through which HUD supports homeless services providers, known as the Continuum of Care (CoC) program. Funds for the CoC program are made available to local communities, which are also called Continuums of Care. Nearly every community in the country has become part of a CoC, with more than 400 CoCs, including those in the territories, covering most of the country. Homeless youth providers, including RHY providers, compete for CoC funding. Local communities establish CoC advisory boards made up of representatives from local government agencies, service providers, community members, and formerly homeless individuals who meet to establish local priorities and strategies to address homelessness in their communities. The CoC plan that results from this process is meant to contain elements that address the continuum of needs of homeless persons: prevention of homelessness, emergency shelter, transitional housing, permanent housing, and supportive services provided at all stages of housing. HUD distributes these funds through an annual competition. Funds for a CoC can be awarded based on a preliminary need amount (which is based on a formula) or on the CoC's Annual Renewal Demand (ARD) amount, whichever is higher. Due to lower funding levels in recent years, all CoCs have been limited to the ARD amount even if the preliminary need amount is higher. Project applicants serving individuals who are homeless in a community (e.g., nonprofit organizations, units of government, etc.) submit a project application that is subsequently submitted by the CoC lead entity, otherwise known as the collaborative applicant. HUD issues an annual notice of funding that sets the criteria for the type of projects and priorities that will be funded in a given year.

CoC program funds may be used to serve youth who are defined as homeless under the HUD definition of homelessness. The funding announcement for FY2015 is the second (after the FY2013-FY2014 announcement) to specify that CoCs may score points in the application process in relation to serving youth. As part of the FY2015 competition, HUD included a priority for addressing youth homelessness as part of the CoC program competition. Specifically, the announcement notes that "CoCs should understand the unique needs of homeless youth and should be reaching out to youth-serving organizations to help them fully participate in the CoC.... When evaluating the performance of youth programs, CoCs should take into account the specific challenges faced by homeless youth." In addition, 15 points are available that can be awarded for addressing youth homelessness, including to CoCs that (1) have strategies for addressing the unique needs of unaccompanied homeless youth and the existence of a proven strategy that addresses homeless youth trafficking and other forms of exploitation; (2) demonstrate an increase in the number of unaccompanied homeless youth (up to age 24) served who were residing on the streets or in places not meant for human habitation prior to ending a project for homeless individuals; (3) demonstrate a plan to increase funding for unaccompanied homeless youth programs; (4) describe how they collaborate with local education authorities and school districts to assist in identifying individuals and families who become or remain homeless and informing them of eligibility of services; and (5) demonstrate the extent to which youth service providers and education providers and CoC representatives have participated in each other's meetings over the past 12 months (including how the CoC collaborates with the McKinney-Vento local education liaisons and state education coordinators under the McKinney-Vento Education for Homeless Children and Youths program).

The majority of CoC program funds are used to renew existing grants. However, even if a CoC has very few or planned projects to respond to youth experiencing homelessness, providers may still be able to access funds. The funding process allows CoCs to reallocate funds from an existing project to a new one if they decide that a new project would be more beneficial than an existing one. The FY2015 round of CoC funding allowed CoCs to reallocate funding to Permanent Supportive Housing or Rapid Re-Housing projects for homeless youth, among other specified populations. In addition, CoCs may qualify for additional funds to create new permanent supportive housing projects to serve unaccompanied youth who come directly from the streets, in addition to other populations.

HUD has otherwise encouraged CoCs to partner with Runaway and Homeless Youth program grantees. In guidance to HUD grantees, HUD emphasized the need for such coordination: "Homeless youth are more multi-jurisdictional than any other homeless population and may interact with adults from educational, child welfare, juvenile justice, and/or homelessness systems. It is therefore critical that CoCs collaborate with schools, child welfare agencies, juvenile justice systems, and, if applicable, projects funded under HHS' Runaway and Homeless Youth Program." Some leaders in the runaway and homeless youth community have suggested the ways that RHY providers can play a more active role in the CoC process even if they are not competing for funds, such as by reading and rating the local applications for CoC funding each year. These stakeholders assert that such participation can help providers understand the CoC's priorities and the extent to which youth are served. They posit that RHY providers could work together closely to improve the chances that youth services will be funded in the CoC: "One or two strong, collaborative or multi-agency endorsed applications to [the] CoC can have a much greater chance at winning a funding award than many competing applications from a variety of youth providers."

Stakeholders have further suggested that RHY providers could collaborate with homeless service providers who work with young adults under age 25 that compete for CoC funding, such as by providing targeted services to this population or contracting to train their staff about the needs of this population. The preamble to the proposed regulations for the program, issued in April 2014, notes that HHS strongly encourages grantees to collaborate with their local CoC, with the goal of ending youth homelessness. The National Alliance to End Homelessness, an organization representing the interest of groups devoted to ending homelessness, has articulated that HHS should explicitly encourage and incentivize this coordination by including it as a factor that is assessed as part of the grant review process for the Runaway and Homeless Youth program.

Vulnerable Populations

Certain groups of youth are vulnerable to running away or becoming homeless. These include lesbian, gay, bisexual, transgendered, or questioning (LGBTQ) youth; those involved in foster care and the juvenile justice system; and youth who are sex trafficked. These groups of youth are not mutually exclusive, and have many of the same underlying issues—stemming, in part, from a lack of family support—that can contribute to their becoming homeless. The amendment to Opening Doors in 2012 emphasized the need for supporting these groups in particular. Policymakers could consider the role of the Runaway and Homeless Youth Act in strengthening assistance to these vulnerable populations and ensuring that RHY providers are equipped to address their sometimes unique circumstances.

LGBTQ Youth

LGBTQ youth appear to be overrepresented in the homeless population, often due to being forced out of their homes when they come out to their families about their sexuality. In five studies of unaccompanied youth in mid-size and large cities, between 20% and 40% of respondents identified as gay or lesbian. In addition, a nationwide survey of 354 organizations serving youth who were homeless in 2011 and 2012 found that LGBTQ youth make up about 40% of their clients. The survey further found that nearly half (46%) of youth who identified as LGBTQ ran away because of family rejection of sexual orientation or gender identity. The survey also found that 40% of providers did not provide services that address the most commonly cited factor that contributes to their LGBTQ clients' homelessness—family rejection. Many providers who were surveyed stated that they had a "great deal of experience" working with LGBT youth, but some did not. Providers identified a range of issues that were barriers in improving their efforts to prevent or address LGBTQ youth homelessness, including lack of funding (32% to 36%, depending on the funding source); difficulty in identifying the population (20%); the fact that serving these youth is not central to their mission (14%); and a lack of information and training on LGBTG youth (9%).

Efforts are underway at FYSB to assist this population by awarding funding under a three-year cooperative agreement in September 2013 to build the capacity of TLPs in serving LGBTQ youth. The grant seeks to develop information about serving the LGBTQ youth population experiencing homelessness, such as through efforts to identify innovative intervention strategies, determining culturally appropriate screening and assessment tools, and better understanding the needs of LGBTQ youth served by RHY providers. In addition, HHS's proposed regulations for the program specify that grantees must provide training that is sensitive to "complex social identities" of youth, including their gender identity and expression and sexual orientation.

The Runaway and Homeless Youth Act does not specifically address LGBTQ youth issues. Congress may consider whether reauthorization of the act should include such provisions and whether current efforts are adequate. For example, some stakeholders have identified concerns that the act does not require grantees to adopt nondiscrimination policies to protect the well-being of LGBTQ youth, or explicitly require training expressly targeted at these youth. In 2009, the American Bar Association (ABA) and the National Network for Youth (NN4Y) developed a model state statute that seeks to ensure that homeless youth service providers adopt inclusive, nondiscrimination policies for LGBTQ youth. The model provides guidance on adopting nondiscrimination policies, including on the basis of gender identity and expression.

Recent research has also suggested that HHS could provide more extensive training and technical assistance on meeting the needs of LGBTQ youth. A 2014 study funded by HHS examined the strategies of four grantees receiving BCP, TLP, and/or SOP funding for identifying and serving LGBTQ youth. The study identified that RHY providers would likely benefit from "specification, dissemination, and evaluation of models for serving LGBTQ youth effectively." The report also specified that technical assistance or training on LGBTQ issues would help agencies in areas without access to local LGBTQ resources, or establishing a forum for providers to share information. The ABA/NN4Y model state statute and other publications outline the types of training topics that could be covered by runaway and homeless youth providers in serving LGBTQ youth, such as approaches to working with families of LGBTQ youth and how to communicate sensitively with youth about sexuality, sexual orientation, and gender identity.

Legislation introduced in the 114 th Congress ( H.R. 1779 and S.Amdt. 290 to S. 178 ) would amend the Runaway and Homeless Youth Act to include a statement of nondiscrimination on the basis of sexual orientation and gender identity or expression (and other characteristics). Both would allow an exception if sex segregation or sex-specific programming would be necessary to operate the program, except that the grantees would be required to provide comparable services to individuals who cannot be provided with such programming.

Sexually Trafficked Youth

Runaway youth are particularly vulnerable to becoming victims of sex trafficking and other forms of sexual exploitation. Runaways may be perceived as easy targets for traffickers because they often cannot go home and have few resources. A federally funded study found that approximately 1.7 million youth under age 18 had run away from home or were forced to leave their homes at some point in 1999. While away from home, an estimated 38,600 (2.2%) of these youth were sexually assaulted, were in the company of someone known to be sexually abusive, or were engaged in sexual activity in exchange for money, drugs, food, or shelter. The Dallas Police Department also found a strong correlation between sex trafficking and runaway status: the more times a child runs away, the greater the likelihood that he or she will be victimized. Other research, including studies examining prostitution in Boston, Chicago, and San Francisco, has found that the majority of prostituted women were runaways.

Shelter and services for trafficked victims who are transitioning from "the life" of prostitution appear to be available on a limited basis. As background for a 2012 colloquium on supports for child victims of sex trafficking, a working group surveyed organizations that provide residential and other services to victims. Over 50 organizations responded to the survey, and together they reported having the capacity to provide specialized services for 1,684 child victims and shelter for 226 child victims. Given that the number of child victims is believed to be much higher, the shelter and services that are available may only reach a fraction of children needing supports.

In 2012, the President's Interagency Task Force on trafficking (established by the Trafficking Victims Protection Act) coordinated a strategic plan on services for victims in the United States. The plan specified that runaway and homeless youth providers are part of a broader response to sex trafficking that involves multiple sectors and organizations. (Some runaway and homeless youth providers have long served youth who are victims of sexual exploitation. Amendments to the Runaway and Homeless Youth Act in 1994 ( P.L. 103-322 ) first specified a role for providers in responding to youth sexual exploitation. These amendments created the Grants for Prevention of Sexual Abuse and Exploitation program, which is now referred to in law as the Sexual Abuse Prevention program and commonly called the Street Outreach program (SOP). As currently enacted, the program seeks to provide street-based services to youth "who have been subjected to, or are at risk of being subjected to, sexual abuse, prostitution, or sexual exploitation." In addition, BCP and TLP providers can often offer immediate support to youth without some of the same barriers of other residential options. For example, they have the ability to accept youth in the middle of the night and can offer longer-term placements to boys and transgendered youth who might otherwise have difficulty finding places to stay.

Nonetheless, the capacity for runaway and homeless youth agencies to respond to the needs of sex trafficking victims is believed to be limited. These settings are often not equipped to provide intensive services for victims or recognize the trauma they have experienced. They also often have time restrictions imposed by funding sources on the length of stay, which, given their unique needs, makes serving victims of sex trafficking difficult. RHY providers and other providers may not recognize the signs of sex trafficking. Even if providers do recognize these signs, youth may choose to leave, given that shelter providers are required to report suspected abuse and neglect, including sexual exploitation.

The federal strategic plan calls for greater supports for RHY and other social service providers in aiding victims of trafficking. The plan articulates that these providers "need training and support to expand their screening protocols to identify those who are trafficking victims and to provide appropriate services and referrals." The plan also lays out action steps that HHS can take to prepare RHY providers in responding. HHS is currently working on such efforts. With support from HHS/ACF, four Runaway and Homeless Youth program grantees have collaborated with the FBI on its Innocence Lost initiative to recover victims of child sex trafficking. These grantees developed a set of standards for working with victims of trafficking that have been used to provide training and technical assistance to grantees.

Separately, HHS/ACF awarded FY2015 funding for three cooperative agreements to implement demonstration projects to provide coordinated case management and direct victim assistance to domestic victims of a "severe form of trafficking in persons." Case management can include service plan development, counseling, monitoring and developing services, monitoring and evaluating client progress, and ensuring clients' rights are protected. Direct victim assistance involves the development of individualized service plans that are tailored to meet the victims' needs.

Whether Congress wishes to address sex trafficking in the Runaway and Homeless Youth Act may depend on how it envisions the role of providers in responding. For example, if it envisions a broader role, it could specify that BCP and TLP providers can or should provide shelter to sexually trafficked youth, or require the programs to coordinate with other entities in the community to respond. Some stakeholders have suggested that the term "prostitute" should be struck from the authorizing language for the SOP, and replaced with a term reflecting that youth are forced or coerced into providing sexual acts. This is consistent with federal trafficking laws that treat children involved in commercial sex acts as victims.

The Justice for Victims of Trafficking Act ( P.L. 114-22 ), enacted in May 2015, expands on the types of research and other projects that HHS should prioritize under staff training on runaway and homeless youth issues. The training areas also now include (1) the behavioral and emotional effects of severe forms of trafficking and sex trafficking, (2) responding to youth showing effects of such trafficking victimization, and (3) agency-wide strategies for working with runaway and homeless youth who have been sexually victimized, including victims of sex trafficking. P.L. 114-22 also specified that in addition to serving runaway and homeless youth, and street youth, the Street Outreach Program is to serve youth who have been subjected to, or are at risk of being subjected to, severe forms of trafficking in persons or sex trafficking. The law separately enables funding to be created from a newly created Department of Justice block grant under the Trafficking Victims Protection Act (TVPA) to deter domestic child human trafficking. Funding may be used for the salaries and associated expenses of retired federal law enforcement officers who assist law enforcement in finding homeless and runaway youth, including salaries and associated expenses for these officers.

Similarly, pending legislation to reauthorize the Runaway and Homeless Youth Act ( H.R. 1779 and S. 262 ) would make multiple amendments to the law to address trafficking. For example, they would require BCP and TLP applicants to develop "an adequate plan" for runaway and/or homeless youth who are victims of trafficking in persons or sexually exploited, and require applicants to annually report to HHS on the number of youth served who are victims of a severe form of trafficking in persons (as defined under TVPA) or sexual exploitation.

High-Risk Youth

Youth experiencing homelessness appear to be at elevated risk for a variety of negative outcomes, including problems in school, mental health and behavior disorders, and engaging in high-risk behaviors such as drug use, risky sexual behavior, and criminal activity. Some TLP providers may not want to admit "hard-to-serve" youth because they lack the specialized services and supports to serve this population. Stakeholders have asserted that this can amount to providers serving only those youth who have the fewest needs and therefore can more readily transition to school, work, or other productive pathways. In comments to HHS about the proposed rule, the National Network for Youth (on behalf of the organizations they represent) raised concerns about the 90% rate that was set for safe and appropriate exits from the BCP and TLP. They suggested that 80% of BCP and 60% of TLP exits should be to safe and appropriate settings because "if the outcome measure is set too high, programs would be dissuaded from serving extremely high-risk runaway and homeless youth.... These programs often have wait lists because the need for services is larger than the capacity of existing programs (due to limited resources) and many programs could choose to serve the lower-risk runaway and homeless youth in order to increase their likelihood of meeting the proposed (unrealistic) outcome measures."

Interaction with Child Welfare and Juvenile Justice Systems

The Runaway and Homeless Youth Act specifies that services provided by BCP grantees are intended to be an alternative to involving runaway and homeless youth in the law enforcement, child welfare, and juvenile justice systems. Still, some of these youth are served by Runaway and Homeless Youth program providers while involved with foster care or juvenile justice or upon leaving those systems, and runaway and homeless youth advocates have raised concerns that Runaway and Homeless Youth program programs receive "little to no funding or recognition" for doing so. Some stakeholders have raised concerns that these other systems do not fully address the needs of some young people, who are then served by the runaway and homeless youth system.

As noted in the 2007 HHS report to Congress, youth transitioning from the juvenile justice and foster care systems are particularly vulnerable to becoming homeless. In recent years, about 7% of youth in the BCP reported having spent some time in foster care and 6% of youth had been in the juvenile justice system at some point in their lives. About 20% of TLP youth have spent time in foster care and nearly 10% have been in the care of the juvenile justice system at some time in their lives. In addition, youth who run away often have a history of involvement in the foster care system. On the last day of FY2012, states reported that almost 5,000 foster children (1% of all foster children) had a current placement of "runaway." A study of youth in Illinois who ran away from foster care between 1993 and 2003 found that the average likelihood of an individual running away from foster care placements increased over this time period. Research on youth who emancipate from foster care suggests a nexus between foster care involvement and later episodes of homelessness. Estimates of homeless youth who are reported as having been in foster care range from 21% to 53%. In an often-cited study of youth who had emancipated from foster care in three states, over one-third had experienced homelessness between the time they left care and age 26. The research literature has similarly documented a connection among juveniles and young adults released from secure detention or correction facilities and becoming homeless, although the data on this population are not as reliable. Some studies have found that homeless adults had high rates of prior incarceration, including while they were juveniles. Further, research has identified a number of challenges that youth are likely to confront when reentering the community, including problems with family and living arrangements. Young people who are homeless also have relatively high levels of involvement with the juvenile justice system.

The National Network for Youth has articulated that given scarce resources, RHY providers should receive greater financial support on behalf of the youth they serve from these systems. In its April 2014 proposed regulations for the Runaway and Homeless Youth Program, HHS provides guidance on coordinating services for these other populations. For example, the rule would add provisions that grantees are not required to provide services that substitute for those provided by juvenile justice, child welfare, or other systems that are legally responsible to youth who are under their supervision. As discussed in the preamble to the proposed rule,

the purposes of these provisions is to provide a clear demarcation between services that are the legal and financial responsibility of other programs, and services that are the responsibility of the Runaway and Homeless Youth Program. Because the availability of federal funds varies among programs, and where Federal funds are available the matching rates usually vary, other State and local agencies have financial incentive to blur these lines. We strongly encourage grantees to take steps [to] prevent other programs from displacing their costs on these programs while also providing continuous service to youth.

Policymakers might consider the extent to which the act should reflect language that is similar to the regulations, or whether RHY providers should coordinate with child welfare and juvenile justice agencies. Current child welfare policies address youth who have run away and/or are homeless. The Child Abuse Prevention and Treatment Act (CAPTA) directs states that receive CAPTA state grant funds to prevent and respond to child abuse to certify that CAPTA-funded programs and training address the unique needs of unaccompanied homeless youth, including access to enrollment and support services. In addition, CAPTA community-based grants allow funds to be used for resources, opportunities, and prevention services for these youth. Separately, HHS is providing child welfare funding for grants to develop and implement interventions for youth who have a history of child welfare involvement and are at-risk of homelessness. Grantees can use these funds to test an intervention model that will help young people in or aging out of care make a successful transition at home, at work, in school, in the community, and in adulthood. These outcomes are consistent with the goals of USICH's Framework to End Youth Homelessness .

Proposed Monitoring and Outcome for the Runaway and Homeless Youth Program

The Reconnecting Homeless Youth Act of 2008 required that within one year after its enactment (i.e., October 8, 2009), HHS issue rules that specify performance standards for public and nonprofit entities that receive BCP, TLP, and SOP grants. In developing the regulations, HHS was to consult with stakeholders in the runaway and homeless youth policy community. The law further required that HHS integrate the performance standards into the grantmaking, monitoring, and evaluations processes for the BCP, TLP, and SOP. On April 14, 2014, HHS issued a notice of proposed rulemaking (NPRM) that seeks to implement new performance standards and other requirements for grantees receiving funds under the Runaway and Homeless Youth program.

According to the NPRM, FYSB undertook a process for consulting with a wide range of stakeholders about the performance standards. The proposed rule includes 10 proposed performance standards, which are outlined in Table A-1 . The NPRM also specifies that the grantmaking process will give priority to providers that (in past years) have demonstrated high performance under these standards.