First and foremost, UMFS acknowledges all the effort that was taken in drafting the 2011 proposed standards. UMFS Staff appreciate all of the opportunities for open communication the State has provided during this revision process.

Regarding the overall content of the proposed standards, most appears clear and reasonable. Specific areas where we felt further clarification and guidance would be helpful are noted below:

22VAC40-131-190. Home Environment.  

S. The applicant shall maintain documentation that household pets receive tests, inoculations, and licenses as required by law.

Clarification needed: does this mean that all vet records are needed for all indoor and outdoor pets or just what are the parameters around this? Also, what specific documentation would be needed in the resource/adoptive parent files to meet this requirement?

22VAC40-131-210. Provider training and development.

Clarification needed as to whether these training topics are required for International families as some of the topics are only pertinent in domestic adoption cases.

22VAC40-131-180. Home Study Requirement

O. A home study conducted for the purpose of parental placement or placement of a child by the licensee shall remain valid for a period of 36 months from the approval date of the study. For adoption cases, before finalization of an adoption in which more than 18 months have passed since the completion date of the study, the licensee may obtain additional state criminal background checks on the applicants and all other adults living in the home of the applicant.

Question: so is it optional to run background checks after 18 months if the adoption hasn’t finalized rather than a requirement?

22VAC40-131-340. Service Plans

Question: does this include children through Child Specific Recruitment (Adoption) programs? (They may not be physically with us, but are receiving services.)

22VAC40-131-510.Provisions for adopting children with special needs:

A. The licensee shall ensure that children with special needs, as defined by § 63.2-1300 of the Code of Virginia, who are legally free for adoption are registered with the Adoption Resource Exchange of Virginia within 30 days of termination of parental rights unless an adoptive family has been identified.

Concern: we have no authority over DSS workers to ensure that this will happen within that timeframe

D. The licensee shall ensure that necessary and appropriate services and treatment are provided to children with special needs, including arranging for necessary services after the final order.

Concern: could be a huge undertaking depending on the case – what are the parameters or guidance around this?

22VAC40-131-250. Intake, acceptance, and placement.

H. Prior to accepting a child for placement in a foster care home, treatment foster care home, short-term foster care home, or an independent living arrangement, the licensee shall gather, review, and document the following information in the child's file:

Question: this makes it sound like the documentation needs to be done for the items laid out in numbers 1 through 8 before the placement of the child is made. We currently collect all this information prior to; however; the documentation of it is typically completed within 5 days of the placement. It may be challenging completing it all prior to placement, especially in those instances when there’s an urgency for placement

Question: There didn’t seem to be a place within the proposed standards that provided guidance around what documentation is required when a child is placed but is discharged prior to 30 days. If a child comes in to care  due to an Emergency Removal Order, is placed in a TFC home, and then the Judge orders them back home at the Preliminary Hearing or a placement disrupts  prior 30 days , what paperwork is required to be completed?

One final question: If these pass, what is our timeframe for implementation?

Thank you for your time and consideration. We’ve appreciated the opportunity to review the proposed standards and provide our comments.

Respectfully,

Nanette Jarratt

John Jenks

United Methodist Family Services