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  11:24 pm
Commenter: WitnessWorks Foundation for a Culture of Life

Rights Talk Betrays Disinclination Toward Parenting's Sacrificial Nature

The WitnessWorks Foundation was established to assist those working to reinvigorate or reform the civil institutions that have failed us, and to facilitate the good works of those attempting to build new institutions that will comprise a culture of life.  Fundamental to that effort is the good work done by faith-based charities, which are nearly almost more effective than the alternatives.  Also fundamental to this effort is a strengthening of marriages and fostering of those doing the hard work of raising children and not just acquiring them.This proposed regulation would present a severe setback on all three fronts.  It is anti-faith, anti-marriage, and anti-parenting.

We concur, in part, with the comments of the National Council for Adoption, in particular where the NCFA states as follows:

"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[s]...."

Most significantly, however, the proposed regulation would completely ignore the welfare of the children who benefit from faith-based adoption services.  

A child is not some thing to which all persons have a right for heir own self-actualization, and an adoption agency is not some common carrier that must take all comers and allow equal access for all to children in need.  Children need parents, preferable a husband and wife married to each other and with an awareness that they are taking on a responsibility for the children's welfare first and foremost above other concerns and personal priorities.  Parenting is essentially sacrificial.

Our laws should not create an adoption license for individuals whose very demand for equal access, when numerous studies demonstrate that children benefit immensely from a traditional family structure, betrays a fundamental disorientation from the proper perspective of a parent.    

As NCFA so aptly put it, "[T]here 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."

Forcing traditional adoption service providers, who are often faith-based in their perspective, either to ignore the best interests of the child or to cease providing the adoption service altogether -- just because it is politically incorrect to admit that children fare better when they have a father and a mother who are married to each other -- constitutes a tremendous disservice to the children whose lives hang in the balance.

The proposed rule must not be promulgated into law in its current form. 

CommentID: 16448