22 VAC 42-11-710 Should not be applicable to post dispositional secure juvenile detention program.  Board Juvenile Justice standards require that Post D residents have a plan with in 5 days of placement.

22 VAC 42-11-720 Sections C and E of this should not apply to post dispositional detention programs because of Va section 16.1-284.1 is more restrictive in requiring monthly progress reports.  Max time in Post D program not to exceed 180 days.

22 VAC 42-11-810 This proposal creates undue hardship when dispending medication to numerous detainees.  Also inconsistent with Board of Nursing Medication Aide Training.

22 VAC 42-11-860 This standard should not be applicable to detention centers, as Board of Juvenile Justice Standards require plans for the management of resident behavior.  The average lenght of stay in a detention home is 23 days, making it hard to comply with the 30 day admission timeframe developing a plan for the detainee.