Definitions - Should these definitions include respite parents as well.
       Dual approval process - the definition states at the end foster and/or adoptive - the premise of dual means both so the or should be ommited.  Foster parent - the definition should include "understand and support reunification" .  Resource parent - this definition should also include approved before the word provider.

22VAC40-211-30 - (B) - fourth line should include the word "of " after approval  (C) should be inclusive of CPS checks as well.  (E) The requirement states and any other adult in the home - suggestion to omit in the home.  There could be a supportive person outside of the home transporting the child.

22VAC40-211-40 - (B) - The statement says that upon submission of a completed application the department is responsible for completing a homestudy - should there not be any training first?(D) Three references per person or a total of three? (F) (4-b) Unclear about the intent of this sentence - Is able to sustain positive and constructive relationships with others in thier care??? (4-e) - Is ther a list of appropriate motivations for fostering or adoption?  Ambiguous language (4-6) - It does not seem to make sense to keep a confidentiality form in the child's file when it is required to be in the parents file.  - This section should include references to a back up plan, supportive persons, ability of person to accept birth parents (or not)...

22VAC40-211-50 (C) 1 - In an effort to go paperless this seems to add to the file in tremendous ways, OASIS documents placements - information can easily be gathered.  The resource parents file should contain the parents information.  (C) 4 This section should include information on medical care authorization, visiting plan, service plan, court dates....

22VAC40-211-60 (D) - This provides that the family is fully approved if he meets all other requirments...and is enrolled in and completes...  Does this replace the emergency approval process and is it open to any and everyone and not just family and/or kin?

22VAC40-211-70 - Standards for the home of the provider.  (A) Does this stipulation refer to all persons in the home? A-3 Comfortable sleeping furnishings - as evident by????  (I) 3 - The provider shall store any firearms...activated safety mechanisms - what is it?.  (I) 4  - ensure??  request verification of provider compliance - what does that mean? (I) 6 - What are the stipulations when the provider is also a daycare provider?

22VAC40-211-100 - B-4 How frequently is it recommended? B-7 Is a home study addendum necessary - the information is in reference to the reevaluation.  The homestudy would become very lenghty for NDHS as we do our reevals annually. (C) Seems as though this statement does not go far enough - if there are issues which document significant changes.... seems as though there should be actions taken further than an addendum in the file.  (D) reads strictly for small agencies at the larger agencies this would be cumbersome to the director - the supervisor can sign off on this document of the program manager not the director.

It is NDHS's contention that extending the reeval timeframe to three years and mandating criminal checks every 4 years is not consistent with bringing the public and private agencies closer in the requirements and regulations.  There would be a reevaluation of a family without the benefit of an updated clearance.   On page 3413 of the regs, third paragraph last two sentences - "The cost is likely exceeded by the benefit of increased rest for affected children.  Increased rest will improve affected children's health and ability to learn". Not sure what the thought process is here, and the age of 16 months does not seem to have a significant foundation.  Age 2 should be sufficient.  Also the children may spend more time awake seeing as though they have been separated.  The top of page 3414 the sentence ends with ... without haveing the care of affected children be adversely affected.  Seems as though it can be reworded so not to sound redundant.

Are these regulations an attempt to bring the public and private agencies more in line with expectations and responsibilities of workers and providers?