Matthews Center is a member of VAISEF and fully supprts the position paper to include the following:

12VAC35-56-300-B-7:  The interpretation of this regulation states that individuals are not allowed begin working with children prior to the completion of the background check.  However, it often takes three to five weeks to receive the results of the criminal background check.  It will be very difficult to hire staff members when they are unable to start working for three to five weeks pending the results of the criminal history background check.  This creates difficulty in staffing our programs particularly those in rural areas where there is a smaller applicant pool. 

Recommendation:  We certainly understand that for the safety of the children we serve, we need to ensure the competency and safety of the people who are working with them.  Therefore, we recommend that staff members be allowed to work with children in a training capacity prior to the results of the criminal background check coming back.  As part of this training capacity, new staff would train with supervisors and never be left alone with the students until the results from the criminal background history came back.

12VAC35-56-310-C:  Given the amount of time required for both initial training and annual retraining, it is difficult to find time within the calendar to hold the additional 15 hours of training as required by this regulation.  Further, it can often be expensive in that staff members may have to be paid overtime in order to have the time in the schedule to complete the 15 hours of training.  The additional training is costly to programs both in purchasing materials and the potential for overtime salaries.

Recommendation:  We recommend this regulation be removed and programs have the non-mandated option of providing additional training to improve the quality of their services.

12VAC35-56-910-D:  This regulation states a resident must be checked on every 15 minutes whereas the Human Rights regulations require a student in timeout be returned to the group within 30 minutes.  The inconsistency between these regulations does not make it clearly written and easy to understand.

Recommendation:  Align this regulation with the Human rights regulation to remove the inconsistency.

Thank you for the opportunity to commemt

Sincerely,
Kimberli A. Collett

Director of Education Matthews Center