There are a variety of housing options available to youth who have demonstrated the skills/competencies to live in an independent living arrangement. Whatever option is selected by the youth, it must be stable and safe and in a community setting that allows the youth full access to services and resources in order to fully develop independent living skills.  Housing options include the following:

• Single dwelling (house, apartment, mobile home);
• Shared housing;
• Boarding home;
• Dormitory (college program); or
• Subsidized housing (HUD-Section 8).

Youth in an ILA are allowed to have roommates, however, ILA is not to be used as a substitute for a relative licensure to provide a form of maintenance for the family, including the biological parent whose rights have been terminated. Placement with a safe, supportive adult is always ideal over an Independent Living Arrangement whenever possible. If placement with an adult caregiver is the plan for the youth, another placement code should be used instead of ILA.

ILA shall not be used in situations where the youth is living with a parent. Foster care is a form of substitute care for children whose safety or well-being requires they be removed from the home of their parent(s). If the parent of the foster youth resides in the resource home, the foster youth is no longer “removed from the control of his parents” per RSM0 211.011 nor is the youth “unattended by parent” per RSMo 210.481(4).

Maintenance payments cannot be made to the resource provider if the child’s own parent(s) is residing in the resource home per Federal Child Welfare Policy Manual Section 8.3A.3. When youth enter into an ILA, it is an opportunity to discuss living agreements and understandings at the time of placement to promote independence, clarify new roles, and establish mutually agreed up on expectations.

ILA shall not be used as a placement with friends or family members who are unable to meet licensure requirements. If an adult exercises authority over the youth or has in the past, or the youth is paying “rent” to a family member or former foster parent while residing in the same residence, this is not an appropriate ILA placement.  

Youth in an ILA shall not “rent” a room or apartment from a foster parent or parent.  ILA is meant to be a community setting for independence.  Renting from a parent or foster parent can result in complications as these persons have had authority over the youth in the past and leave the youth in a vulnerable position, such as homelessness, should the relationship change.

A youth in an ILA shall not be providing supervision or authority over any other youth residing in the home. Consequently siblings of youth in an ILA may not be “placed” with the youth as an ILA placement. If a sibling meets all of the ILA requirements, the siblings may however reside together as housemates. For example, a 15 year old and an 18 year old may not reside together in ILA placements as a 15 year old does not meet the age requirements. However, an 18 year old and a 19 year old sibling may reside together as they both meet the age requirements for ILA. Youth working on their own successful transition from foster care should not be put in a position of having parental authority over a sibling, and youth under the age of the ILA requirements are in need of parental authority.

If a youth is case managed by an agency outside of Children’s Division or Foster Care Case Management, such as the Department of Mental Health or a group home program that is not licensed but in which staff reside, this is not an ILA. Youth in an ILA should be able to manage their own physical and mental health needs on a daily basis, are able to come and go on their own, and have entered into a lease agreement to reside in the dwelling. Youth who qualify for an ILA should have a plan to exit to independence, not to the care of another agency.

There are some community agencies providing services similar to transitional living program services via an apartment or a group home setting that are not licensed and contracted with Children’s Division to provide this service. These programs are not approved to provide services for youth in foster care so youth should not be placed with them and coded as an ILA. Staff in these facilities are not monitored by Children’s Division. If a youth is in need of a Transitional Living Program, a referral shall be made with an agency who is contracted with Children’s Division to provide this service. 

If a youth resides in a community program that provides living arrangements such as Job Corp, this is an ILA placement and the youth shall receive maintenance directly to them as they are living independently. The youth may visit a resource family on the weekend however the majority of the time the youth is residing in a program and thus it is not a foster care placement. 

Related Practice Alerts and Memos:

2-10-20 – CD20-11 – Independent Living Arrangements