| Action | Revise standards to meet current industry practices. |
| Stage | Proposed |
| Comment Period | Ended on 7/27/2007 |
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27 comments
I have read the proposed changes to the regulations and I agree with many of the changes proposed but a few have drawn a red flag.
What information is availble that equates master degrees with the ability to better manage a business. I have read over and over again that this requirement is to ensure the children receive quality care. How? There are many adults who may not have a masters who are equipped with the proper information on how to run a business. In addition to that, what percentage of adults with masters are willing to work with some of the more difficult populations? What is the impact of the changes on the current CRF's.
The information talked about there already being homes out there that meet the new standards. How many? How many will be looking for new staff in the same pool that the new applicants for a CRF will be using.
"APPLICANTS WILL NOT RECIEVE A LICENSE UNTIL YOU HAVE A CAO, BACK UP CAO, PROGRAM DIRECTOR, AND SUFFICIENT NUMBER OF STAFF TO RUN THE FACILITY. "- how many more months will this add to the application period?
It is my understanding that there has been a large number of requests to open a CRF. Believe it or not there is still a need for quality homes for our children. Why is this a problem if the homes are following your standards and providing quality care. For those that are not following the standards (new and seasoned homes) follow your procedures for getting them to comply with the rules.
There seems to be a need for smaller CRF's that provide more individual care. Is there information on the size of the proposed CRF's. That may affect the larger CRF"S.
The next area that raises concern is the $500 application fee. This fee is suppose to cover training. What training? Applicants are informed that they are respnsible for properly training thier staff and themselves and that licensing is there to make sure that they are following the guidelines. What trainings are going to be given in addition to what is already given. Is there some type of shortage of funds that our tax money doesn't cover. As a business person, I would want to know where the money is going and how training is currently being funded and a list of the additional training to be provided. It is very difficult to open up a CRF. The amount of money you must have available, the house that may remain empty until you get your liscense (+6 months), and the funds to fully furnish a house adds up. Add $500 more? Why?
Finally, the changes to the background checks. Before, owners were given the option to determine for themselves who to hire. They took into account how long ago the offense occurred. Someone who committed a crime 10-15 years ago, is probably not the same person they were 10 years ago. I am speeking of crimes that do not involve a minor. I understand that the safety of the children comes first. Is there a time frame at which the offense could have been committed? Or is it a blanket that covers the adult years of an applicant? How does that affect existing homes?
I understand that these proposed changes to the standards are suppose to protect the child. That is the priority. I would just like to see statistics, surveys, audits, something concrete to support the information being given.
Many of us are in this business to do our part for the kids that live in our neighborhoods, go to school with our kids and eventually will be productive citizens in our community.
S.Highsmith, Owner-Back 2 Basics
The proposed (and revised emergency standards) regarding staffing requirements for the CAO and program director are very restrictive and not fully justified. The minimum requirements for 1) a master's degree and 2) a minimum number of years working in a children's residential facility are requirements that will exclude a lot of qualified individuals from these positions.
A review of Maryland and North Carolina's standards will show that a bachelor's degree and a minimum number of years of programmatic work experience is sufficient.
The Program Administrator shall have at least the following qualifications:
(a) A bachelor’s degree from an accredited college or university;
and at least three years experience in the human services field with at least two
of the years in a supervisory or administrative capacity; or
(b) A master’s degree from an accredited college or university; and
at least one year of experience in a supervisory or administrative capacity.
North Carolina
(1) Administrator. The Administrator shall be responsible for the general management and administration of the agency in accordance with licensing requirements and policies of the governing body. The Director employed after the effective date of these standards must have at a minimum a bachelor's degree from a school, accredited by the Association of Colleges and Schools and at least four years experience in a human services program of which a minimum of two years has been in administration.
I propose that the standards be revised for the minimum education requirement for the CAO and program director positions. A bachelor's degree in a human services related field (social work, psychology, counseling) should fulfill the minimum education requirement.
I propose that the standards be revised for the minimum work experience requirements. Minimum work experience should encompass programmatic experience in other areas in the human services arena including, but not limited to, demonstrable KSAs in the areas of foster care, social work, child protective services, nursing, and child care facilities. Work experience should not be limited to a number of years in a children's residential facility because the KSAs required for these positions are generally transferrable from various human services settings. In addition to three years human services programmatic work experience, the CAO and program director should have a minimum of two years work experience in a staff supervisory or administrative capacity.
Furthermore, I would propose that there is no variance in the standards for minimum qualifications for the positions of CAO and program director since, in many instances, the program director serves as the back-up CAO.
Lastly, I would like to recommend that the Standards for Interdepartmental Regulation of Children's Residential Facilities regarding the staffing qualifications for CAO and program director follow similar qualifications for the program director position under Virginia's Standards for Licensed Child Day Centers as they relate to minimum education degree and programmatic work experience requirements. These standards, revised in 2005, are less restrictive but also address the issue of providing quality care to children - albeit in a different setting.
I have reviewed the proposed Interdepartmental Standards and I am requesting that the following items be considered for revision:
22 VAC 42-11-640.H--Records should be retained and disposed of in compliance with the Library of Virginia's General Schedule 24 relative to maintenance of juvenile records. In the case of detention facilities, maintaining records indefinitely is a fiscal burden to the tax payer and serves no purpose since these records are duplicative of most information maintained by the courts.
22 VAC 42-11-860--This item should be N/A for secure detention. Secure facilities should be permitted to implement behavior management programs conducive to the needs of a secure environment.
22 VAC 42-11-810.F.6--Medication should be administered consistent with the 22 VAC 40-72-670 and the Board of Nursing approved training for medication administration; i.e. the recording of "actual time" in the proposed standards is not considered as an industry standard.
Finally, I request that a definition be provided for "post-disposition" that is consistent with language contained in VA Code 16.1-284.1 regarding the placement of juveniles in a secure facility.
I have read the proposed Interdepartmental Standards and request the following additions/revisions:
22 VAC 42-11-10 Definitions – Please add a definition of “post-dispositional detention” or “post-dispositional detention program” to ensure that references to post-dispositional detention in the Standards reflect placements under section 16.1-284.1 of the Code of Virginia.
22 VAC 42-11-710 Initial Strategies and Objectives – I recommend that the last sentence be revised as follows, “The requirements of this section do not apply to secure detention facilities, except when a juvenile is confined in a post-dispositional detention program.” Clarification is necessary to ensure that youth sentenced to weekends and other short-term sentences are excluded from the requirements of this Standard.
22 VAC 42-11-720 Service Plan/Quarterly Reports – As above, I recommend that subsection J be revised as follows, “The requirements of this section do not apply to secure detention facilities, except when a juvenile is confined in a post-dispositional detention program.”
22 VAC 42-11-860 Behavior Support – I recommend that this Standard not be applicable to secure detention facilities. The first reference in the proposed Standards to “behavior support needs” is in 22 VAC 42-11-680 Application for Admissions, which does not apply to court ordered placements. It would therefore follow that other references to behavior support needs and plans would not be applicable to court ordered placements.
22 VAC 42-11-870 – Time Out – Since this is addressed in Board of Juvenile Justice Standards in 6 VAC 35-140-550 Disciplinary Process and 6 VAC 35-140-560 Room Confinement & Isolation, I ask that this Standard not be applicable to secure detention facilities.I have reviewed the proposed standards and request consideration be given to the following revisions.
22 VAC 42-11-500.E: Recommend “DJJ certified facilities shall obtain the approval of the regulatory authority before any video or audio monitoring is permitted" be removed. Other standards adequately protect the privacy of children.
22 VAC 42-11-640-H: Requires the admission face sheet to be retained permanently. This is a fiscal, time and space burden on the facility. This information is kept by the courts and is a duplication of records.
22 VAC 42-11-710: “Initial Objectives and Strategies” should not be applicable to secure detention. The Department of Juvenile Justice regulations address this in a more stringent manner.
22 VAC 42-11-810 F.6: Requires the Actual time of medication administration. Recommend the regulation be revised to mirror medical industry standards and Medication Agent Training by the Board of Nursing.
22 VAC 42-11-860: Requires a Behavior Support plan within 30 days of admission.. Recommend secure detention be exempt from this regulation. The average length of stay in predisposition detention is twenty three (23) days.
Recommend consistant language when referring to “Post Dispositional detention” as defined in this document as "sentenced to a juvenile detention home for a period exceeding thirty days as found in 16.1-284.1.B Code of Virginia". This revision applies to:
22 VAC 42 11 710
22 VAC 42 11 720 J
22 VAC 42 11 760 A
22 VAC 42 11 790 B.6
22 VAC 42-11-800.H
22 VAC 42-11-900.B.3a
22 VAC 42 11 990 C
Recommend using a standard phrase “Does not apply to secure detention except when a juvenile is sentenced per COV 16.1-284.1.B”
Thank yuou for your time and consideration.
Joanne Smith, Executive Director
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B. A person who assumes or is designated to assume the responsibilities of a position or any combination of positions described in these standards shall:
1. Meet the qualifications of the position or positions;
2. Fully comply with all applicable standards for each function; and
3. Demonstrate a working knowledge of the policies and procedures that are applicable to “his” specific position or positions.
Note: B. 3. Should not be gender specific. Suggest using “this” position or his/her position.
Video and audio monitoring shall be permitted only in common hallways and common areas. All such monitoring shall have the approval of the regulatory authority and if licensed by DMHMRSAS the approval of the Office of Human Rights. DJJ shall obtain the authority before any video or audio monitoring is permitted. Video and audio monitoring is prohibited in bathrooms, dressing areas and bedrooms.
Note: Recommend “DJJ certified facilities shall obtain the approval of the regulatory authority before any video or audio monitoring is permitted”, be removed. Other standards protect the privacy of children.
H. The face sheet shall be retained permanently unless otherwise specified by state or federal requirements.
Note: Ask that this standard not apply to secure facilities. It is an extreme burden for large facilities that admit hundreds of residents each year and it is kept on file in both the Court Service Unit and the Juvenile Tracking System.
Within three days following admission, individualized, measurable objectives and strategies for the first 30 days shall be developed, distributed to affected staff and the resident, and placed in the resident’s record. The objectives and strategies shall be based on the reasons for admitting the resident. The requirements of this section do not apply to secure detention facilities, except when a juvenile is confined in post-dispositional detention.
Note: This should not be applicable to secure detention and post-dispositional detention programs because Board of Juvenile Justice Standard have a five day plan that is addressed
F. A medication administration record shall be maintained of all medicines received by each resident and shall include: 1. Date the medication was prescribed; 2. Drug name; 3. Schedule for administration; 4. Strength; 5. Route; 6. Actual time administered; 7. Identity of the individual who administered the medication; and 8. Dates the medication was discontinued or changed.
Note: Recommend the regulation be revised to agree with Medication Agent Training received by detention employees through out the Commonwealth and give the one hour window to document that medication was administered.
A. Within 30 days of admission, the provider shall develop and implement a written behavior support plan that allows the resident to self-manage his own behaviors. Each individualized plan shall include: 1. Identification of positive and problem behavior; 2. Identification of triggers for behaviors; 3. Identification of successful intervention strategies for problem behavior; 4. Techniques for managing anger and anxiety; and 5. Identification of interventions that may escalate inappropriate behaviors.
B. Individualized behavior support plans shall be developed in consultation
with the:1. Resident; 2. Legal guardian; 3. Resident’s parents, if applicable; 4. Program director; 5. Placing agency staff; and 6. Other applicable individuals.
C. Prior to working alone with an assigned resident each staff member shall
demonstrate knowledge and understanding of that resident’s behavior support plan.
Note: Recommend secure detention is exempt from this regulation. The average length of stay in predisposition detention is twenty three (23) days.
Submitted by Krystal R. Kimrey, Executive Director
I have reviewed the proposed Interdepartmental Standards and I am requesting the following items be considered for revision:
22 VAC 42-11-710. Initial Objectives and Strategies: This standard should not be applicable to post-dispositional secure detention program placements because Board of Juvenile Justice Standards require that post-dispositional residents have a plan, in consultation with the Court Services Unit, within 5 days of placement (6 VAC 35-140-707.B.2)
22 VAC 42-11-720. Service Plan/Quarterly Reports: Sections C and E of this standard should not apply to post-dispositional detention program placements because the Code of Virginia Section 16.1-284.1 is more restrictive in requiring monthly progress reports. In addition, the maximum amount of time that post-dispositional detention program residents can be in a Post-D program is 6 months.
22 VAC 42-11-810 Medication: Documentation of the "actual time administered", Section F.6, creates an undue hardship when dispending medications to numerous detainees, and it is inconsistent with the Board of Nursing's Medication Aide Training.
22 VAC 42-11-860 Behavior Support:This standard should not be applicable to secure detention centers, as Board of Juvenile Justice Standards require plans for the management of resident behavior. The average length of stay in a detention home is 23 days, making it impossible to even comply with the 30 day admission timeframe for developing the plan. It is not feasible or possible for detention staff, with such limited knowledge of residents who are court-ordered in, who do not have definitive timeframes for staying, and who are not there for treatment services, to develop individualized behavioral program. To maintain facility safety and security, it is best practice to have a behavior management program that is conistently applied to all residents in detention, which again, is required by BJJ Standards.
22 VAC 42-11-810.F.6--Medication should be administered consistent with the 22 VAC 40-72-670 and the Board of Nursing approved training for medication administration; i.e. the recording of "actual time" in the proposed standards is not considered as an industry standard.
22 VAC 42-11-10 Definitions – Please change the definition from “Confined in Post-Dispositional Program” to “Post-Dispositional Program”. In addition, this definition should reflect the wording of section 16.1-284.1 of the Code of Virginia.
22 VAC 42-11-860 - Behavioral Supports should not apply to detention facility. The focus of a correctional facility is not therapuetic, but a matter of safety and security to the child and community.
22 VAC 42-11-710 Should not be applicable to post dispositional secure juvenile detention program. Board Juvenile Justice standards require that Post D residents have a plan with in 5 days of placement.
22 VAC 42-11-720 Sections C and E of this should not apply to post dispositional detention programs because of Va section 16.1-284.1 is more restrictive in requiring monthly progress reports. Max time in Post D program not to exceed 180 days.
22 VAC 42-11-810 This proposal creates undue hardship when dispending medication to numerous detainees. Also inconsistent with Board of Nursing Medication Aide Training.
22 VAC 42-11-860 This standard should not be applicable to detention centers, as Board of Juvenile Justice Standards require plans for the management of resident behavior. The average lenght of stay in a detention home is 23 days, making it hard to comply with the 30 day admission timeframe developing a plan for the detainee.
Proposed standard 42-11-500E - This standard should exempt secure facilities due to safety and security issues. The privacy issues for youth are adequately provided for in other standards.
Proposed standard 42-11-860 - Pre-dispositional detention facilities should be exempt. This standard, as is, requires diagnosis, observation and implementation which is not consistent with the mission, function, capabilities nor time frames of pre-dispositional detention facilities.
22 VAC 42-11-500.E. prohibits video and audio monitoring in bathrooms, dressing rooms, and bedrooms. This standard should be "N/A" for secure detention since video and audio observation is heaviliy relied upon to protect the safety and security of our population. Restricting observation would jeapardize the safety of youth who at at risk of suicide or self-destructive behavior. The expectation of privacy in a secure detention facility should be superceeded by a responsibility to protect the safety of youth. Direct observation would be required as a substitute to video monitoring which would increase the cost to tax payers unnecessarily.
22 VAC 42-11-500.E Should not apply to Secure Detention. If this regulation is adopted without the exemption of Secure Detenton the likelihood of a tragedy in Secure Detention will increase. The expectation of privacy in secure detention should never superceeded the safety of the child. This standard should be N/A as applied to Secure Detention
This standard prohibits video and audio monitoring in bathrooms, dressing areas and bedrooms. This standard should not be applicable to secure detention. Secure detention facilities use cells monitored by video and audio for the safety of children who are suicidal, self-mutilators and for medical reasons. Monitored cells are also used in admission/release areas while juveniles are awaiting processing.
Joanne Smith
Middle Peninsula Juvenile Detention Commission
Please consider the following comments in regards to the proposed standards:
22VAC42-11-500.E: The use of video or audio monitoring capabilities in relation to a suicidal/self-injurious or medically qualified resident is a security function that enhances the safety and welfare of the child. Such capability is normally augmented with recording capability which provides a record of the actions of a child in need in addition to constant supervision by control room operators and normal cell checks. This standard places a cumbersome burden upon the facility and is unnecessary in light of other standards that protect the privacy of our residents.
22VAC42-11-860: Requires a Behavior Support plan with 30 days of admission. The average length of stay in secure detention is well under the 30 day threshold for this standard and yet an occasional case remains beyond the 30 day stay but this is unknown at the time of admission. Without exempting secure detention, the occasional and unbeknown case will serve to violate the standard. Secure pre-disposition detention should be exempted from this provision.
I am a Trustee for the not-for-profit Boys’ Home in Covington VA. I offer my comments in the spirit of ensuring the safety of children entrusted to our care while also ensuring the continued viability of Boys’ Home to provide the vital services needed by those same children. I know that the Virginia Association of Independent Specialized Education Facilities (VAISEF) has submitted very specific recommendations to the Proposed Regulations.
I support the VAISEF recommendations and request that they be adopted.
I emphasize that without these modifications to the Proposed Regulation, Boys’ Home’s ability to fulfill its mission is jeopardized. It is jeopardized not because the rules address safety of residents; it is jeopardized because the absolute nature of the wording leaves no room for de minimus infractions to be rectified. To comply absolutely will be excessively onerous. The narrow definition of the educational background of the CAO is but one example of how the Proposed Regulattion usurps the breadth of governance a Board of Trustees needs to oversee the Boys’ Home.
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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.
I have read over the proposed regs and do not see the justification for the following:
1) $500 non-refundable application fee; why should an individual/organization pay the state office an exhorbitant application fee to provide a much-needed service to the Commonwealth of Virginia?
2) The education and work experience qualifications are too narrowly defined and are not justified. There is other relevant work experience that should be considered in addition to direct work experience in a children's residential facility. There are professionals who have worked with and advocated on behalf of children in various roles and organizations who might be better qualified to serve in the role of CAO or Program Director than someone who has worked in a facility (as a youth counselor, van driver, etc.). There should be exceptions to the educational requirement and the work requirement.
Proposed standard 42-11-500.E
Should not apply to secure detention due to reasons already expressed by the other concerned detention center superintendents.
I write this as a member of the not- for- profit Board of Trustees of the Boys' Home in Covington, VA. I fully support the recommendations made by the Virginia Association of Independent Specialized Education Facilites ( VAISEF). The specific recommendations with the outlined "Reasoning" made by VACIF have merit and should be adopted in full.
The regulations as currently proposed would put inherent restrictions on the Board of Trustees and on the operation of the mission of the Boys' Home which has served this Commonwealth for the needs of young boys since 1905. Without the modifications as proposed in writing by VAISEF, the program at Boys' Home may be compromised. With adjustments in the proposed regulations, all parties would be better served and the valid intent of the Legislature would be upheld.
G.Chandler Williams , 2729 Kenmont Terrace, Midlothian, VA
I am writing as a Trustee of the Boy's Home in Covington, VA. Boy's Home just celebrated it's 100 year anniversary and now it appears that it's operation could be hindered due to undue and unneed regulation. In a review of the proposed regulations it appears that they are designed to cover all types of homes and treatments, therefore hurting some and helping others. While I realize the intent of the regulations is the safety of the children, our residents are not institutionalized and our mission will be imparied by undue regulation.
There are four areas of concern. First, I think that the term "Substantial Compliance" should be used instead of "Total Complaiance". Using the term "Total" could allow areas not related to the mission or safety of the children hurt programs or institutions.
Secondly, combining all four departments, Social Services, Juvenile Justice, Education, and Mental Health, is too comprehensive and therefore make the regulations too restictive for some homes like the Boy's Home. Third, proposed Executive Director's educational levels and the veto power enjoyed by Licensing means that the responsiblity of the Boards will be eliminated.
Finally, additional training requirements will add to costs and in many cases it is not needed. Perhaps, a review of what training is actually needed in each facility, not universal requirements.
As a Trustee of Boys' Home of Virginia, I have grave concerns about the ability of this storied institution to continue its legacy to the state and nation if all of the VAISEF recommendations are not adopted.
And as a parent, I know from experience that "one-size-fits-all" rules and guidance for child development do not work at all, much less effectively. I strongly encourage this state agency to preserve Boys' Home's ability to offer its students the unique developmental opportunities through the proven, quality child care and educational systems it has provided since 1906.
Timothy Cordle
Williamsburg
Thank you to all members of the Committee for Interdepartmental Regulation of Children’s Residential Facilities for your work and efforts in maintaining and improving services provided to vulnerable children in the Commonwealth of Virginia. I understand the task set before you was and is of great magnitude considering the short amount of time given.
After reading the proposed regulations and comments posted above, I cannot help but conclude and recommend that the proposed Revised Standards be disapproved or substantially revised.
The fundamental problem with the Interdepartmental Regulations of Children’s Residential Facilities and the proposed changes is that there is only one set of codes regulating many inherently different types of organizations. After a short perusal of the comments above, it is clear that more restrictive facilities object to certain proposed regulations for opposite reasons that less restrictive facilities do so.
In an attempt to create a set of codes with a mentality of “one size fits all”, you have been forced to meet in the middle and thereby not ensure that services provided to residents are appropriate for their needs. Diversity of programs and children should be encouraged, not restricted. I am confident that more time, thought, and research would allow for more factually-based regulations and the separation/creation of different sets of codes to be developed based on the type of facility and children served (somewhere between 3-6 different types based on program type and population served).
I support the VAISEF recommendations and request they be adopted. I also recommend the education and work experience requirements for Program Directors and CAO’s be revised so as not to be so narrowly defined.
I support the recommendations of the Virginia Association of Independent Specialized Education Facilities to the proposed Standards for Interdepartmental Regulations for Children’s Residential Facilities. Further, I believe the proposed standards contain the following inconsistencies:
Concerning the qualifications of the CAO, I find the list of acceptable college majors does not address the full range of responsibilities specified by 22 VAC 42-10-260-A. Duties relevant to facility management, budget and finance and personnel management are to be included in the CAO’s job description but are not normally associated with duties relevant to social work, psychology, or counseling. The inclusion of business related majors, along with education and nursing, as acceptable majors, would better recognize the complexity of the CAO position and certainly expand the pool of qualified applicants.
Concerning the General Requirement for “full compliance with sufficient applicable standards . . .” 22 VAC 42-11-90-B, paragraphs 3a and 4b state that the annual and triennial licenses may be issued when the provider “substantially meets or exceeds the requirements of the Interdepartmental Standards . . .” In my opinion, the term “substantial compliance” provides the reviewing agency the flexibility to consider all available information, and the provider to make the reviewing agency aware of all available information, prior to the declaration of a “Violation.”
I write as a child advocate who is concerned the proposed revisions of the standards to meet current industry practices will, in fact, inhibit the ability of many successful albeit less restrictive environments to continue to meet the best interests of the children in their care. I urge more thorough research into this complex issue, taking into account the wide range of services and needs of the children served.
I do not feel it is prudent to restrict the range of levels of care available for out of home care, thus forcing overly limiting regulations upon less restrictive programs. Such adoption of one code to regulate the diverse options available in child placement puts an undue burden on the private providers to children with special needs. The adoption would also seem to negate the decades of positive results and successes that less restrictive programs throughout the Commonwealth have enjoyed. The proposed regulations would have a disincentive effect.
I support the adoption of the recommendations as put forth through the members of the Virginia Association of Independent Specialized Education Facilities (VAISEF). Thank you.
Thank you for your time in developing and updating the Standards for Interdepartmental Regulations for Children's Residential Facilities. I fully support your mission of "keeping children safe."
One of areas that I would like to comment on is restoration of the substanial compliance. Although a licensed facility does well in most areas during the licensing process just a few i's that are not dotted or t's that are not crossed can be very costly to the facilities licensure. Every facility regardless of how structured usually has several violations. Although you do the very best job possible something gets past your attention or is left incmplete.
A college degree does not necessarily mean that a person is qualified or capable of full filling a job position. There should be a provision for those individuals who have years of knowledge and experience working in children's residential homes and caring for the needs of children and adolescents. Although someone has a college degree does not mean that they better understand, care about, or has what it takes to do the job when it comes to caring for children.
As far as the $500 non-refundable fee for licensing. For small non-profit agencies or homes this may propose a hardship with limited or non-existant benefits.
As the debate continues over the proposed regulations please take into consideration children's homes that are are non-profit, not institutional, and operate as a home in order to provide children with a safe, productive, less restrictive environment.
Debra Parks, MSW
I am a member of the Board of Trustees of the Boys' Home, a not- for- profit organization located in Covington, VA., I fully support the recommendations made by the Virginia Association of Independent Specialized Education Facilites ( VAISEF). and believe they should be adopted.
First, I think that the term "Substantial Compliance" should be an option, used in addition to the terms "Total Compliance" or "Not in compliance." This would allow minor problems to not be a concern for would-be students and their parents and/or guardians.
Next, it appears to me that developing one set of regulations affecting the four departments, ie, Social Services, Juvenile Justice, Education, and Mental Health, is an overly-broad grouping of institutions under one "umbrella," possibly resulting in the regulations not being restrictive enough in some instances, and too restictive as to others, such as the Boy's Home.
Third, the proposed regulations outlining an Executive Director's required education, etc. take away options previously enjoyed by the Board of Directors, ie, the option of choosing an executive director based upon life experience, attitude and ability rather than solely the degree(s) the individual might have earned.
Finally, additional training requirements will add to costs and in many cases this training is not necessary.