I have read over the proposed regs and do not see the justification for the following:

1) $500 non-refundable application fee; why should an individual/organization pay the state office an exhorbitant application fee to provide a much-needed service to the Commonwealth of Virginia?

2) The education and work experience qualifications are too narrowly defined and are not justified.  There is other relevant work experience that should be considered in addition to  direct work experience in a children's residential facility.  There are professionals who have worked with and advocated on behalf of children in various roles and organizations who might be better qualified to serve in the role of CAO or Program Director than someone who has worked in a facility (as a youth counselor, van driver, etc.).  There should be exceptions to the educational requirement and the work requirement.