Please consider the following comments in regards to the proposed standards:

22VAC42-11-500.E:  The use of video or audio monitoring capabilities in relation to a suicidal/self-injurious or medically qualified resident is a security function that enhances the safety and welfare of the child.  Such capability is normally augmented with recording capability which provides a record of the actions of a child in need in addition to constant supervision by control room operators and normal cell checks. This standard places a cumbersome burden upon the facility and is unnecessary in light of other standards that protect the privacy of our residents.

22VAC42-11-860:  Requires a Behavior Support plan with 30 days of admission.  The average length of stay in secure detention is well under the 30 day threshold for this standard and yet an occasional case remains beyond the 30 day stay but this is unknown at the time of admission.  Without exempting secure detention, the occasional and unbeknown case will serve to violate the standard. Secure pre-disposition detention should be exempted from this provision.