22 VAC 40-151-320.B.1        Requirements for Child Care Staff: Requiring a baccalaureate degree is reasonable requirement, as it demonstrates that the prospective worker is intelligent, independent, motivated, and self-disciplined. However, specifically requiring a degree in human services is too limiting and presumptuous. Most liberal arts undergraduate degrees are designed to provide a general and well-rounded education which is applicable and valuable in most professions. Also, a baccalaureate in science, mathematics, engineering, etc. should indicate an individual’s ability to learn, not rule him/her out when he/she is demonstrating an interest in a profession of helping others. Recommended language change to 22VAC 40-151-320.B.1:       1. Have a baccalaureate degree in human services;

22 VAC 40-151-590               Interstate Compact on the Placement of Children: Approval through the Interstate Compact process is appropriate when a resident is involved with the Department of Social Services or the Domestic Relations and Juvenile Courts regarding issues of custody, adoption, foster care, continuation of services, and/or supervision. However, when a student is placed exclusively by his/her parent(s) and the child is not receiving services from either state agency, the Interstate Compact Process is not appropriate. Interstate Compact approval does not provide any additional protection for parentally placed children beyond what state regulations already provide. The Interstate Compact process for parental placements only places an unnecessary burden on parents who are taking the initiative and financial responsibility for helping educate their children. It seems pertinent to amend the standard to reflect the need for Interstate Compact approval only when a child is part of the DSS or Juvenile Courts system. Recommended language change to 22 VAC 40-151-590.A:                         A. Documentation of the prior approval of the administrator of the Virginia Interstate Compact on the Placement of Children, Virginia Department of Social Services shall be retained in the record of each resident admitted from outside Virginia. The requirements of this section shall not apply to a facility providing documentation that the administrator of the Virginia Interstate Compact has determined the facility is statutorily exempt from the compact's provisions; nor shall the requirements apply to residents who are parentally placed without public funds.

22 VAC 40-151-800               Behavior Support:                 A Behavior Support Plan is appropriate when problematic thinking/feeling is manifested as externalized and seemingly out-of-control behavior. However, such a plan is not appropriate when problematic thinking/feeling is internalized or manifested as manipulative behavior, drug/alcohol abuse, or emotional withdrawal.   These latter behaviors may not have identifiable “triggers”, may not involve inappropriate levels of “anger and anxiety”, and (particularly in cases of manipulation and drug/alcohol abuse) may involve deliberately calculated misrepresentations by residents. A behavior support plan is appropriate for residents with histories of out-of-control behavior and for residents who first manifest those behaviors while in placement.            Recommended language change to 22 VAC 40-151-800.A:                  A. Within 30 days of admission, the provider shall develop and implement a written behavior support plan that allows the resident to self-manage his own behaviors, when the resident has history of out-of-control behaviors at intake. If a resident first manifests out-of-control behavior while in placement, the provider shall develop a written behavior support plan within 30 days of the incident. Each individualized plan shall include: