Thank you for your time in developing and updating the Standards for Interdepartmental Regulations for Children's Residential Facilities. I fully support your mission of "keeping children safe."

One of areas that I would like to comment on is restoration of the substanial compliance.  Although a licensed facility does well in most areas during the licensing process just a few i's that are not dotted or t's that are not crossed can be very costly to the facilities licensure.  Every facility regardless of how structured usually has several violations. Although you do the very best job possible something gets past your attention or is left incmplete. 

A college degree does not necessarily mean that a person is qualified or capable of full filling a job position.  There should be a provision for those individuals who have years of knowledge and experience working in children's residential homes and caring for the needs of children and adolescents.  Although someone has a college degree does not mean that they better understand, care about, or has what it takes to do the job when it comes to caring for children.

As far as the $500 non-refundable fee for licensing.  For small non-profit agencies or homes this may propose a hardship with limited or non-existant benefits.

As the debate continues over the proposed regulations please take into consideration children's homes that are are non-profit, not institutional, and operate as a home in order to provide children with a safe, productive, less restrictive environment.

Debra Parks, MSW