I write as a child advocate who is concerned the proposed revisions of the standards to meet current industry practices will, in fact, inhibit the ability of many successful albeit less restrictive environments to continue to meet the best interests of the children in their care.  I urge more thorough research into this complex issue, taking into account the wide range of services and needs of the children served.

I do not feel it is prudent to restrict the range of levels of care available for out of home care, thus forcing overly limiting regulations upon less restrictive programs. Such adoption of one code to regulate the diverse options available in child placement puts an undue burden on the private providers to children with special needs. The adoption would also seem to negate the decades of positive results and successes that less restrictive programs throughout the Commonwealth have enjoyed. The proposed regulations would have a disincentive effect.

I support the adoption of the recommendations as put forth through the members of the Virginia Association of Independent Specialized Education Facilities (VAISEF). Thank you.