I support the recommendations of the Virginia Association of Independent Specialized Education Facilities to the proposed Standards for Interdepartmental Regulations for Children’s Residential Facilities.  Further, I believe the proposed standards contain the following inconsistencies:

Concerning the qualifications of the CAO, I find the list of acceptable college majors does not address the full range of responsibilities specified by 22 VAC 42-10-260-A.  Duties relevant to facility management, budget and finance and personnel management are to be included in the CAO’s job description but are not normally associated with duties relevant to social work, psychology, or counseling.  The inclusion of business related majors, along with education and nursing, as acceptable majors, would better recognize the complexity of the CAO position and certainly expand the pool of qualified applicants.

Concerning the General Requirement for “full compliance with sufficient applicable standards . . .”   22 VAC 42-11-90-B, paragraphs 3a and 4b state that the annual and triennial licenses may be issued when the provider “substantially meets or exceeds the requirements of the Interdepartmental Standards . . .”  In my opinion, the term “substantial compliance” provides the reviewing agency the flexibility to consider all available information, and the provider to make the reviewing agency aware of all available information,  prior to the declaration of a “Violation.”