Type over this text and enter your comments here. You are limited to approximately 3000 words.

I write as a member of the Board of Trustees of Boys' Home. I hope that my comments will reflect the dedication which this institution has always exhibited in its attention to the care and safety of the boys which it serves. It is my hope that the recommendations which the Virginia Assoc. of Independent Specialized Education Facilities (VAISEF) have made will be adopted.

As I have studied the proposed regulations, it has become patently obvious to me that without adoption of these recommendations, Boys' Home's ability to carry out its mission will in great jeopardy. Because the proposed regulations are to cover such a wide variety of services (at least four departments), our program then would become essentially an institutionalized one, not one that could respond to the individual needs of the residents.

I am concerned about four areas in particular: (1) the restoring of substantial compliance dropped during previous changes; (2) The fact that because the proposed regulations cover four departments (Social Services, Juvenile Justice, Education, and Mental Health) they would be highly restrictive the the Boys; Home program; (3) The restrictive nature of the regulations regarding the Executive Director's acceptable educational fields completely undermines the major responsibility of the Board of Trustees of the institution;, and (4) The cost of implementing of additional training regulations would be injurious to independent agencies such as Boys' Home.