Virginia Regulatory Town Hall
Agency
Department of Social Services
 
Board
Coordinating Committee for Interdepartmental Regulation of Children's Residential Facilities
 
chapter
Standards for Interdepartmental Regulation of Children’s Residential Facilities [22 VAC 42 ‑ 11]
Action Revise standards to meet current industry practices.
Stage Proposed
Comment Period Ended on 7/27/2007
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5/30/07  12:00 am
Commenter: R. Lewis

Oppose staffing qualification standards
 

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. 

Maryland

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.

 

CommentID: 430