I am a Trustee for the not-for-profit Boys’ Home in Covington VA.  I offer my comments in the spirit of ensuring the safety of children entrusted to our care while also ensuring the continued viability of Boys’ Home to provide the vital services needed by those same children.  I know that the Virginia Association of Independent Specialized Education Facilities (VAISEF) has submitted very specific recommendations to the Proposed Regulations.

I support the VAISEF recommendations and request that they be adopted.

I emphasize that without these modifications to the Proposed Regulation, Boys’ Home’s ability to fulfill its mission is jeopardized.  It is jeopardized not because the rules address safety of residents; it is jeopardized because the absolute nature of the wording leaves no room for de minimus infractions to be rectified.  To comply absolutely will be excessively onerous.  The narrow definition of the educational background of the CAO is but one example of how the Proposed Regulattion usurps the breadth of governance a Board of Trustees needs to oversee the Boys’ Home.