This public comment letter addresses proposed changes to the Title IV-E Prevention Services Clearinghouse’s Handbook of Standards and Procedures. We provide our comments on the proposed changes for the Administration for Children and Families’ consideration based on our combined 37 years of experience conducting rigorous impact evaluations in child welfare. Specifically, we comment on the following proposed changes:

1. We support the proposed changes to determining posttreatment follow-up time for assessing outcomes. The changes better reflect the reality of child welfare service delivery; many programs have undefined or variable treatment length.
2. We are generally supportive of the proposed changes to the baseline equivalence requirements. The changes prioritize direct pretests, which are a best practice, and the ability to use neighborhood characteristics provides more options for quasi-experimental designs that rely on administrative data.
3. We support allowing head-to-head comparisons. However, we suggest that if the comparison program has been rated as supported or well-supported by the Clearinghouse, then the program being tested should only have to do equally as well (i.e., not significantly worse) to achieve a rating.
4. We suggest that the Clearinghouse give greater weight to studies focused on the child welfare population when the Clearinghouse has to limit the number of studies reviewed. Families and children who are involved or at risk of being involved in the child welfare system experience unique challenges. 
5. We suggest that reviewers apply a multiple test correction when multiple contrasts are reviewed for a program. This still allows a program to be rated if just one contrast is favorable, but it will prevent false positives for programs with many studies (and thus many contrasts) under review.

We generally support the proposed changes to the Clearinghouse review criteria and standards. It is our view that many of the changes balance the need for rigor with the realities of conducting evaluations with people involved or at risk of being involved with the child welfare system.