Virginia Regulatory Town Hall
Department of Social Services
State Board of Social Services
Minimum Standards for Licensed Private Child-Placing Agencies [22 VAC 40 ‑ 131]
Action Adopt new standards for licensed private child-placing agencies.
Stage Proposed
Comment Period Ended on 4/1/2011
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3/31/11  9:39 am
Commenter: Megan Lindsey, JD; National Council For Adoption

Concern Re: 22 VAC 40-131-170(B)

The National Council For Adoption (NCFA) expresses concern with the proposed changes to the Minimum Standards for Licensed Private Child-Placing Agencies [22 VAC 40 ? 131]  regarding discrimination on the basis of religion and sexual orientation (22 VAC 40-131-170(B)).  While NCFA prefers no religious position nor do we take a strong position regarding the issue of sexual orientation in adoption, we recognize that many well reputed child placing agencies are faith-based and have sincerely held religious beliefs that are in conflict with these prohibitions were they to be enforced to the extreme. In light of the fact that there are many agency alternatives in Virginia to deal with differing viewpoints, we believe that it would not be in the best interest of children to compromise the great work many faith-based agencies do by eliminating their ability to work on behalf of children while still acting in agreement with their sincerely held religious beliefs. We fear this prohibition has the potential to put faith-based adoption service providers in conflict with state regulations based on deeply held religious beliefs and strongly suggest the inclusion of language that allows for a conscientious-objection for faith-based agencies regarding whether or not to work with adoptive families that are outside of their religious faith or to place children with homosexual families.


NCFA believes that there is no right to adopt, only the right of the child to be adopted. The purpose of adoption is to provide the best possible parents for children, not to provide children for adults who desire to parent. Adoption policy and practice should be guided only by the best interests of the child and eliminating faith-based organizations ability to continue in the great work they do is not in the best interests of the many children whose interests faith-based agencies represent.   


CommentID: 16354