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  1:57 pm
Commenter: Jeff Caruso, Executive Director, Virginia Catholic Conference

Opposition to proposed 22VAC40-131-170B

On behalf of the Virginia Catholic Conference, I write to convey opposition to several aspects of the proposed 22VAC40-131-170B, which is part of the proposed Minimum Standards for Licensed Child Placing Agencies.  The Conference is the public-policy agency of Virginia’s Catholic bishops and their two dioceses. 

The proposed 22VAC40-131-170B states: “The licensee shall prohibit acts of discrimination based on race, color, gender, national origin, age, religion, political beliefs, sexual orientation, disability, or family status to: (1) Delay or deny a child’s placement; or (2) Deny an individual the opportunity to apply to become a foster or adoptive parent.”

The Virginia Catholic Conference has consistently opposed the inclusion of “sexual orientation” in discrimination-related legislation considered yearly by the General Assembly.  The basis for the Conference’s opposition is that sexual orientation is manifested through words or actions, and sometimes those words or actions could conflict with the mission, beliefs, and practices of organizations with certain deeply held convictions and religious beliefs regarding the institution of marriage, the family unit, and human sexuality.  This same rationale also undergirds our current opposition to 22VAC40-131-170B. Including “sexual orientation” and “family status” could force some agencies into a choice of whether to follow their own missions or to adhere to the law.  Forcing this choice is unacceptable because it violates the freedom of conscience and diversity of viewpoint upon which our pluralistic society is based.

It is also important to note that some agencies may currently have requirements for prospective adoptive parents regarding age,and may consider religion when making certain placements.   Where this is the case, the proposed 22VAC40-131-170B would force agencies to alter these practices as well.

In conclusion, faith-based agencies play a vital role in the fabric of our Commonwealth, and their right to carry out their mission in the services they provide must be respected and preserved.

Jeff Caruso, Executive Director

Virginia Catholic Conference



CommentID: 16373