Position Paper

Proposed Chapter 131

Standards For Licensed Child-Placing Agencies

 

Volunteer Families, a Virginia Licensed Child Placing Agency (License #co-339-10), is pleased with the effort to revise minimum standards for licensure. As the only agency in the Commonwealth whose expressed mission is to provide a maximum of 21 days of emergency shelter and respite, Volunteer Families especially supports the distinction made in the new standards related to SHORT-TERM FOSTER CARE. After nearly 32 years of service to over 17,000 of Virginia’s at-risk children and youth, we have a great deal of evidence to support that short-term care meets a significant need. We also believe the services that we are able to provide as a licensed agency are in clear congruence with the Virginia Department of Social Services’ new practice model and the National child welfare movement to increase permanency for foster youth. Offering emergency shelter and ongoing respite to at-risk families, before an incidence of abuse or neglect occurs, will help keep families intact in the long run, while immediately serving the best interests and safety of children. However, the previous standards adopted in 1989, set up significant barriers for agencies like ours to meet requirements and conduct our work efficiently and effectively.

 

While we support the short-term foster care distinction, there are several areas in which we believe the recent revisions do not go far enough in removing barriers to quality service provision. The following are Volunteer Families’ suggestions for rewording specific sections of the standards:

 

PROPOSED SECTION 22 VAC 40-131-29 Medical, dental, and psychiatric examinations and care

“Each child shall have a medical examination conducted by or under the direction of a licensed physician no earlier than 90 days prior to placement, except in the following situations.”

1.       “An emergency-placed child shall have up to 60 days following placement to receive a medical examination if a written medical examination no earlier than 90 days prior to placement is not available.”

2.       VOLUNTEER FAMILIES SUGGESTED ADDITION: “In the case of temporary parental entrustment of a child into short-term care or respite, the licensed agency will identify obtaining medical care for the child as a primary service plan goal, and assist the parent and child with meeting that goal in no less than 60 days following placement, if a written medical examination no earlier than 90 days prior to placement is not available.”

REASONING: Frequently, the families seeking short-term care and respite through parental entrustment are by definition in crisis. While agencies like Volunteer Families prioritize the physical health of children, we do not want to restrict families from receiving the emergency help that they seek. This is especially true if the very nature of the situation which has brought them to our door step has also limited their ability to obtain medical care in the last 90 days. As a part of their service plan, we can help these families connect to appropriate medical services, but once their temporary entrustment end, we have no authority to force parents to take their children to a doctor. Since placements with our agency last no longer than 21 days, that places a more stringent burden on our agency to arrange appointments and provide transportation than is placed on other licensed child placing agencies (60 days, as listed in exception #1 above). We also recommend making the above exception applicable to dental exam requirements. 

PROPOSED SECTION 22VAC40-131-230 Monitoring and Re-evaluation of the Host Home

2. The results of an evaluation of the providers' performance to include his:

d. Ability to establish and maintain a consistent and stable environment for each child and including in this evaluation, the identification and resolution of problems or significant changes that occurred in the family since the last evaluation”

VOLUNTEER FAMILIES SUGGESTED ADDITION: “Exception - For re-evaluations of providers of short-term foster care only, instead of addressing the provider’s consistency and stability for each child placed since the last evaluation, the licensee should conduct an overall evaluation of the providers ability to assist the children in their home with transitioning to and from care.”

REASONING: Since the primary goal for short-term care is to provide safe and nurturing shelter during a transitional period in the life of a child, it is of greater importance that the providers understand how to help children successfully transition between home settings, than to provide long-term stability. In addition, because short-term providers typically care for more children over a 36 month period than long-term providers, it is more practical to conduct an overall assessment of the provider’s performance in this area than to look at each child’s case at the time of re-evaluation when they provides does short-term care only.

 

PROPOSED SECTION 22VAC40-131-250 Intake, Acceptance, and Placement

H. 3. A (2). VOLUNTEER FAMILIES SUGGESTED ADDITION: Except in the case of parental placement in short-term foster care or respite, for a child under one year old the admission examination shall consist of a hospital summary and a physician signed report of interim care no older than 30 days that documents the absence of abnormalities or if abnormalities are present the report shall contain an explanation of abnormalities observed. 

REASONING: While it is important for the licensee to capture as much medical information as possible at the point of intake, in the case of parental placement, there may be no to suspect that there are any abnormalities in the child’s development or that the child has been hospitalized since birth. Parental placements are often made without any reported allegations of abuse or neglect by the parent.

N. VOLUNTEER FAMILIES SUGGESTED ADDITION: Except when the placement of the child is an emergency placement or placement intended to last no longer than 30 days, the licensee shall prepare the child for placement and arrange a pre placement visit for the child in the prospective home. If a pre placement visit did not take place prior to the child’s placement, the reasons why it did not occur shall be documented in the child’s file. 

REASONING: The intent of pre-placement visit is to help ensure that a child and a foster family are well-matched for long-term placement. While the licensee can and should use a variety of tools to match children and families prior to placement, a pre-placement visit may not be necessary prior to intended to last longer than 30 days.

PROPOSED SECTION 22VAC40-131-260 Social History

VOLUNTEER FAMILIES SUGGESTED ADDITION: a. Exception – in the case of emergency or short-term placement, education and occupation information for the parents and siblings ONLY are required.

VOLUNTEER FAMILIES SUGGESTED ADDITION: a. Exception – in the case of emergency or short-term placement, medical and psychiatric information for the parents and siblings ONLY are required.

REASONING: This level of detail on the history of extended family members may not be available, nor pertinent, to the child’s short-term care.

PROPOSED SECTION 22VAC40—131-250 Intake Acceptance and Placement

PROPOSED SECTION 22VAC40-131-370