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