Section 4, Chapter 5 (Older Youth Program), Subsection 5 – Independent Living Arrangement

Effective Date:  2-10-20


An Independent Living Arrangement (ILA) is a state-approved and subsidized placement option for youth age 18 and older who cannot return home. The case manager in conjunction with the Family Support Team (FST) determines the youth’s suitability for placement in an independent living arrangement, by assessing the youth’s motivation, abilities, skills and capabilities for living independently and ultimate emancipation from the service delivery system.  Youth in an ILA have a goal of APPLA and must be referred for Chafee Program Services and receiving services prior to the placement being made.

5.5.1   Criteria for Youth Being Considered for an Independent Living Arrangement

Independent Living Arrangements should be the planned placement for youth in out-of-home care and should never be used when a more appropriate placement resource is available for the youth. Although licensure is not involved, the safety and wellbeing of a youth must be ensured. Youth in an ILA should be able to demonstrate competency in life skills, mange his/her own finances, demonstrate responsible conduct, and are attending school and or working. The payment of $402.00 for monthly maintenance is made directly to the youth when they are in an ILA placement. 

Criteria for an ILA are as follows:

  • Youth is at least 18 years of age; Youth under the age of 18 are not allowed to enter into a lease agreement in Missouri, which is vital to provide housing stability. Youth who are age 17 may be considered for an ILA if the youth has obtained their high school diploma or HiSet. Youth who are still attending high school are typically not able to focus on the demands of sustaining an ILA residence thus they should be referred to the Transitional Living Program instead.
  • Youth is under court jurisdiction and in the care and custody of the Children’s Division;
  • There is no likelihood of reunification with parent/legal guardian;
  • Relative care has been explored and is not an option for the youth;
  • The youth does not want to be adopted;
  • The case manager has consulted with the FST and a plan has been completed that specifies how the youth will live;
  • Youth is enrolled and participating actively in the Chafee Foster Care Independence Program;
  • Youth is able to demonstrate competency in life skills;
  • Youth is able to manage his/her own finances and live independently; a community agency provider is not overseeing the placement.
  • Youth has demonstrated responsible conduct for at least 6 months:
  • No criminal law violations;
  • If applicable, school performance is equal to youth’s capabilities; and
  • Responsible money management.
  • Youth is attending an educational or vocational school regularly to the satisfaction of school officials and is gainfully employed; and
  • Youth has assisted or developed their plan for independent living.

5.5.2   Independent Living Arrangement Housing Options

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. 

5.5.3   Independent Living Arrangement Support Services/Systems

Youth in Independent Living Arrangements, while often viewed as doing well and being capable of living “independently”, need as much, if not more support than youth in other placement types as there is not a resource provider in the young person’s life and many have limited personal connections to rely on in the event they experience a crisis, i.e., financial, health, emotional, etc. Consequently, youth in an ILA placement must have two contacts per month, with at least one of these as a visit in their living environment. This level of contact helps to improve outcomes and successful transition of youth exiting state custody. It is critical that the case manager assist the youth in identifying and accessing resources to enhance the prospects for success in the ILA. Specifically, the case manager, youth, and other family support team members should identify, to the extent possible and appropriate, the following support systems:

  • Medical/dental services;
  • Educational/vocational training programs/options;
  • Employment opportunities;
  • Emergency contacts within the agency;
  • Family supports;
  • Religious supports;
  • Community sponsor/mentor; and
  • Others as needed.

5.5.4 Independent Living Arrangement Placement Review Process

An FST or Team Decision Making Placement Stability meeting shall occur prior to a youth moving into an ILA.

For any new placements in which ILA is being considered, PRIOR to placement being made, the Children’s Service Worker shall send the completed ILA Checklist form and the Self-Developed Case Plan for Independent Living Arrangement to the Circuit Manager (CM)/Program Manager (PM) for review. 

The Self-Developed Case Plan for Independent Living Arrangement is used to assist with preparation and budgeting for an initial ILA placement. 

The Independent Living Arrangement Checklist is completed each time a youth is being considered for an ILA. 

After reviewing, the CM/PM will indicate whether the placement constitutes an ILA per the criteria in the Child Welfare Policy Manual. A decision as to whether the placement meets ILA criteria should be determined within 30 days after the checklist is initially received.

If a youth is determined to not meet the criteria for an ILA placement based on the Independent Living Arrangement Checklist or not adequately prepared based on the Self-Developed Case Plan for Independent Living Arrangements, the coding shall not be used and another placement type sought. If the youth is placed in an ILA after meeting the criteria, the Independent Living Arrangement Checklist is reviewed quarterly by the case manager and the supervisor during case consultation. 

If the placement does not meet the criteria for an ILA, and the family support team or court wishes to pursue the living arrangement, a different placement code will need to be used (i.e. RHU, CTO, etc.).

Prior to placement of a youth, appropriate County Children’s Services staff or contracted case agency staff must approve the suitability of the residence. Staff shall use the TLP Advocate and Independent Living Arrangement (ILA) Checklist, CS-TLP-1, which provides a procedure for documenting health and safety requirements specific to an older adolescent placed in an ILA. 

The Independent Living Arrangement Checklist and the CS-TLP-1 shall be completed each time the youth moves to a new ILA to ensure the living environment is safe and meets ILA requirements.

Upon placement in an ILA, the Independent Living Arrangement Checklist is reviewed quarterly by the case manager and the supervisor during case consultation. 

A copy of the Independent Living Arrangement (ILA) Checklist, the CS-TLP-1, and the Self-Developed Case Plan for Independent Living Arrangement shall be placed in the youth’s file in the Older Youth Program section and a copy shall be provided to the Regional Older Youth Transition Specialists upon completion.

5.5.5   Termination of Independent Living Arrangement

An Independent Living Arrangement subsidized and supported by the Division is temporary and should be terminated under the following circumstances:

  • Youth has demonstrated success in living independently and the FST agree that the youth will likely continue to live successfully as an adult in the community and should be released from court jurisdiction;
  • Youth is unsuccessful in living independently and requires placement in a more structured and supervised setting, i.e., transitional living program, out-of-home care or residential treatment;
  • Youth is in runaway status in excess of seven (7) consecutive days and likelihood of his/her returning to care is remote;
  • Youth has entered into a legal marital arrangement.
  • Youth is in active military duty.
  • Youth engages in criminal activity which results in action by the legal system; or
  • Youth is released from court jurisdiction, Division custody, or reaches his/her 21st birthday.

Related Practice Alerts and Memos:

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