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