.

AFGC Comments on Proposed Regulations for LCPA Standards

Adolescent and Family Growth Center, Inc. appreciates the work done by the Virginia Board of Social Services and the workgroup that was assembled  to adopt new regulations for Licensed Child Placing Agencies.   We also appreciate the opportunity to comment on the proposed regulations.

Comments:

22VAC40-131-90.  Policy and Procedures

D. 4. Implementing the child’s detailed back-up emergency care plan when the child’s placement disrupts. 

We have questions about the expectation of this policy.  How detailed would plans need to be and how can the agency plan for all potential contingencies.  A plan for a disruption based on a foster parent becoming ill would look very different than one based on unforeseen changing behaviors of the child in placement. 

22VAC40-131-140 Staff composition and qualifications

AFGC feels that opening up the degree requirements for Executive Directors and  Program Directors will provide agencies with more options in hiring and promoting staff. 

H. 2. An individual with a doctorate degree or masters degree in social work from a college or university accredited by the Council on Social Work Education shall supervise students or interns who perform child placing activities and approve all placement decisions made by the student or intern. 

Given that Child Placing Supervisors do not need a social work degree, this requirement is incongruent.  Also many interns come from programs other than social work and may need to be supervised by individuals with other degrees.  We would recommend that this be changed to allow supervisors or staff with degrees in related fields, be allowed to supervise and make placement decisions.

22VAC40-131-150

B. 1. Prior to assuming the responsibilities of his position in the licensee’s child placing agency and within 30 days of the date of employment, each staff person who has responsibility to work with children and their families or to supervise staff persons who work with children and their families shall receive orientation that includes:  …

There are many orientation activities that can be safely completed as staff are assuming their responsibilities of service and would request this change.

22VAC40-131-190 Home environment

E.  The provider and children in care shall have access to a working telephone in the home.   

Will we receive clarification regarding whether this means that a landline is required in the home or if an available cell phone is adequate?

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

We would recommend that “receive tests” be removed from this requirement, since it is vague. 

H.  Following approval of an applicant, the licensee shall provide the following services and requirements:

1.  The licensee shall provide orientation and on-going training for each provider

Most orientation is provided in pre-service training.  We would appreciate not being required to re do orientation following approval and would recommend that orientation be removed from the above requirement.

22VAC40-131-230

K. The licensee shall maintain documentation in the provider’s file of :

                1.  Each visit and contact made with the provider.

                2.  Each visit made to the home of the provider.

We agree that all contacts should be documented, however home visits and contacts in reference to a particular child are documented in the child’s file, having the documentation in both files would be time consuming, costly and environmentally unfriendly.  We would ask that this requirement be clarified to say that all contacts that are not in reference to a child and therefore not in a child’s record, shall be documented in the provider’s file.   

22VAC131-320 Reports and policies to protect children

E. The licensee shall report any serious incident, accident , or injury to the child to the placing agency, parent or legal guardian and to the department’s licensing agent within 24 hours following the incident, accident or injury. 

It would be helpful to clarify “serious incident.” 

22VAC40-131-220 Visitation and continuing contact with children:

F.  More than on half of the contacts the licensee makes with a child in any calendar year shall be conducted in the child’s placement setting. 

This seems to be for the purpose of supporting services in the foster home.  However there may be cases when intensive work might need to be done in the community or with the school.  We would hope that we would be able to add additional contacts there, without being required to add contacts in the foster home in order to meet this standard.  We would request that the standard clarify that more than half of the required contacts be conducted in the placement setting, this would allow flexibility that additional contacts be in whatever venue would be necessary.