We applaud the State’s decision to mandate pre-service and annual training for all providers, and we encourage the State to fund this mandate.

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Our greatest concern with the Proposed Standards is the implication for kinship     families:

There is no provision for emergency approval; this may increase # of moves for    kids

Will waivers be granted for families unable to obtain a physical exam prior to approval? This could be a substantial cost to families.

Will waivers be granted for co-habituating kinship families?

Will waivers be granted for Barrier Crimes not presenting a safety risk, e.g. 18.2-94?

 

22VAC40-211-10 – Definitions – It would be helpful to define “couple,”e.g. two married heterosexual individuals, two committed heterosexual individuals, two committed homosexual individuals. The issue of approving cohabitating couples, heterosexual or homosexual should be addressed in standards. 

 

22VAC40-211-20A

Mandating the acceptance of “adoption only” families will create an additional burden on staff. 

 

22VAC40-211-30B

To ensure compliance with federal and state laws, standards should provide guidance in a user friendly manner, e.g. specify who must have background checks, providers/all household members over 18.

 

22VAC40-211-40

Add documentation of marriage license and divorce decree, if indicated. Many foster parents become adoptive parents. The adoption process could be delayed without proper documentation up front.

 

22VAC40-211-50

Require that applicants receive “letter of denial”, if appropriate and require applicants to submit “request to withdraw” in writing, if appropriate.

3 year approval period is too long increasing risks to children; background checks should be consistent with renewal period.

Provide allowance to suspend provider’s approval for a period of time, e.g. an adult child moves into the home after release from prison (barrier crime not involving child safety), needs parents’ help in obtaining a job, apt, etc. Under standards, provider home would have to be closed and foster child moved. The provider would have to reapply after resolving family issue. 

 

22VAC40-211-70A3

Sleep furnishings should also be safe, e.g. cribs (22VAC40-110-540)

E. Bedrooms should have two exits

I.5 Medication shall be kept out of reach of children and locked as appropriate