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.