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.