and Applicability

Part II

Organization and Administration 22VAC40-131-30 to100

1.               Sponsorship

2.               Licensee

3.               Office Settings and Conditions

4.               Posting of the License

5.               Conflict of Interest

6.               Licensed capacity and Maximum Caseload Numbers

7.               Policy and Procedures –F. Suggest guidance on implementation of emergency back up plans when placement disrupts. Suggest TFC providers be permitted to have a general statement such as “another approved provider home within agency” to allow for variation internally based on timing and situational emergencies, since not all back up homes will be readily available or appropriate at the time of the unplanned emergency.

8.               Program Evaluation and Improvement
This is a very nice addition to standards!

9.               Received Date for Materials

Part III

Personnel 22 VAC40-131-140

1.               Access to Written Personnel Policies

2.               Job Descriptions

3.               Staff
 These revised definitions are appreciated to allow for greater hiring flexibility across the state and particularly in more rural areas.

o                        Executive Director

o                        Program Director

o                        Child-placing Supervisor

o                        Case Worker

o                        Case Worker Trainee

o                        Students or Interns receiving Professional Training
H.1. Requirement to be supervised by an MSW.  This is the only mention of this specific degree requirement in the new standards.  This may not have been intentional?  Suggest that a Child Placing Supervisor is sufficient to supervise interns or students if the college/university is OK with that qualification (particularly given the new experience requirements in other job descriptions

o                        Volunteers

o                        Consultants

4.               Staff Development 22VAC40-131-150
B.1.&2. Suggest striking verbage “prior to assuming responsibilities” while maintaining 30 day requirement to allow agencies to begin orienting staff to role as training occurs rather than having to wait full 30 days for any responsibilities to begin.
D.E. uses expression "a child-placing agency-managed" file to describe where training documentation is to be kept.  We assume this expression means the Personnel Record for the employee as that is what is prescribed in the Personnel Records section below.

5.               Personnel Records

Part IV

Program Statement and Description 22VAC40-131-170

B.2. Providers will need guidance on this new item of prohibiting discrimination based on ....., 'sexual orientation' and cannot deny the opportunity to become a foster or adoptive parent.  We need to evaluate if this is actually a state endorsement of approving gay & lesbian individuals or couples as foster and adoptive parents.  Is this correct? If so, this will put an end to any ambiguity around the issue, but we will need guidance to other policy sections that seem to restrict this item.