Thank you to all members of the Committee for Interdepartmental Regulation of Children’s Residential Facilities for your work and efforts in maintaining and improving services provided to vulnerable children in the Commonwealth of Virginia.  I understand the task set before you was and is of great magnitude considering the short amount of time given. 

After reading the proposed regulations and comments posted above, I cannot help but conclude and recommend that the proposed Revised Standards be disapproved or substantially revised. 

The fundamental problem with the Interdepartmental Regulations of Children’s Residential Facilities and the proposed changes is that there is only one set of codes regulating many inherently different types of organizations.  After a short perusal of the comments above, it is clear that more restrictive facilities object to certain proposed regulations for opposite reasons that less restrictive facilities do so. 

In an attempt to create a set of codes with a mentality of “one size fits all”, you have been forced to meet in the middle and thereby not ensure that services provided to residents are appropriate for their needs.  Diversity of programs and children should be encouraged, not restricted.  I am confident that more time, thought, and research would allow for more factually-based regulations and the separation/creation of different sets of codes to be developed based on the type of facility and children served (somewhere between 3-6 different types based on program type and population served).

I support the VAISEF recommendations and request they be adopted.  I also recommend the education and work experience requirements for Program Directors and CAO’s be revised so as not to be so narrowly defined.