The Families First Prevention Services Act supported the creation of congregate foster care programs to provide “high-quality residential care and supportive services to children and youth who have been found to be, or are at risk of becoming, sex trafficking victims” -- without defining key terms. This interactive discussion will explore how the NYS model of care was developed from the perspective of a service provider agency and state licensing/oversight agency. Presenters will share successes, lessons learned, and questions yet to be resolved.