I am a member of the Board of Trustees of the Boys' Home, a not- for- profit organization located in Covington, VA., I fully support the recommendations made by the Virginia Association of Independent Specialized Education  Facilites ( VAISEF). and believe they should be adopted.

First, I think that the term "Substantial Compliance" should be an option, used in addition to the terms "Total Compliance" or "Not in compliance." This would allow minor problems to not be a concern for would-be students and their parents and/or guardians. 

Next, it appears to me that developing one set of regulations affecting the four departments, ie, Social Services, Juvenile Justice, Education, and Mental Health, is an overly-broad grouping of institutions under one "umbrella," possibly resulting in the regulations not being restrictive enough in some instances, and too restictive as to others, such as the Boy's Home.

Third, the proposed regulations outlining an Executive Director's required education, etc. take away options previously enjoyed by the Board of Directors, ie, the option of choosing an executive director based upon life experience, attitude and ability rather than solely the degree(s) the individual might have earned.

Finally, additional training requirements will add to costs and in many cases this training is not necessary.