FCASPL 128 (Position Statement on Therapeutic Interventions Funded with Post Adoption Special Services Subsidy)
Family, Children and Adult Services Procedure Letter No. 128
October 31, 2007
TO: All Family, Children and Adult Services Manual Holders
FROM: Helen E. Jones-Kelley, Director

The Ohio Department of Job and Family Services in conjunction with the Ohio Department of Mental Health Services issues the following position statement for agencies to consider as they approve Post Adoption Special Services Subsidy (PASSS) funds to pay for therapeutic interventions for children.

The Post Adoption Special Services Subsidy (PASSS) is a state program designed to provide funds for medical, therapeutic and respite services for adopted children and their families. To receive funds, the family must be experiencing a severe crisis to the point that a disruption of the adoption is eminent and the child is in need of protective services or care by a public agency. Any PASSS service provided must address a pre-existing need or a need that developed from the child's pre-adoptive background issues.

Prior to using PASSS funds, the family's insurance and/or Medicaid shall be utilized, if the service is covered by insurance and/or Medicaid. There are a wide range of therapeutic techniques which may be funded by PASSS based on the unique needs of the adoptive child and the adoptive family's sense of what treatment is most effective, as long as certain safeguards are in place to assure the child's safety and well being.

It is the position of Ohio Department of Job and Family Services (ODJFS) and Ohio Department of Mental Health (ODMH) that:

  • The provision of a physically and psychologically safe environment is a basic foundation and requirement for effective mental health treatment. Creating calm surroundings and establishing positive, trusting relationships are essential to facilitating a person's treatment and recovery.
  • All therapeutic interventions that are provided with PASSS funds shall be administered by Ohio independent licensed providers licensed in psychology, psychiatry, social work, counseling or advanced practice nurse and are expected to adhere to the code of ethics of the licensing body. The provider shall release information to the public children services agency providing payment arrangements for the services and to the child's adoptive parent(s).
  • Interventions involving noncontingent physical restraint or coercion (e.g., "therapeutic holding" or "compression holding"), "reworking" of trauma (e.g., "rebirthing therapy"), or promotion of regression for "reattachment" have no empirical support and have been associated with serious harm, including death, and are therefore not to be a service provided utilizing state PASSS dollars. Specific interventions prohibited from being funded through PASSS include but are not limited to:
  • Face down restraint with back pressure;
  • Any technique that obstructs the airways or impairs breathing;
  • Any technique that obstructs vision;
  • Any technique that restricts the recipient's ability to communicate;
  • Pepper spray, mace, handcuffs or electronic restraint devices such as stun guns; and
  • A drug or medication that is used as a restraint to control behavior or restrict the individual's freedom of movement that is not a standard treatment for the individual's medical or psychiatric condition.


The following chart depicts what materials should be removed from and what material should be inserted into the Family, Children and Adult Services Manual (FCASM).