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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4/1/11  11:57 pm
Commenter: David DePerro, Virginia resident since 1982

Support and love children: Reject the proposed regulation

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Proponents of identity-based politics would use the proposed regulation, if enacted, as a bludgeon against long-established and respected private adoption agencies. The result would be the rapid loss of valued, experienced, and compassionate adoption services to a vulnerable population of Virginia children. As soon as the regulation were passed, strident activists opposed to the constitutionally protected missions of private religious agencies would pursue lawsuits designed to force the agencies to choose between either embracing actions contrary to their missions or ceasing to perform adoptions altogether. Just as bad or worse, bureaucrats empowered with a regulation and enforcement authority would become cops without a badge claiming the backing of the law to harass and intimidate private agencies who are just doing what they have always done: help children. The Commonwealth of Virginia cannot allow wolves in sheep’s clothing to use the language of non-discrimination as a cover to destroy religious conviction and toy with children’s lives in pursuit of political agendas. The Commonwealth should reject the proposed regulations.

Private adoption agencies cannot compromise on what is best for children; they cannot accommodate themselves to a policy that would force them to act knowingly against the best interests of any single child. They cannot sacrifice one child’s welfare, even in the name of serving other children. Therefore, the proposed regulations in practice would force such agencies to cease offering adoptions (and in some cases cease their entire operations).

Lost would be their experience: their knowledge of neighborhoods and communities, schools and families, adoption laws and procedures. Most of all, lost would be the love they give to the children, the love they give to the families—families built to provide the benefits of stability and permanence children need so much in a home. All lost, when agencies close because of a couple new words in a regulation that doesn’t need changing in the first place.

Hardly a hypothetical problem, the forced termination of adoption services has already occurred among private agencies in at least Massachusetts and the District of Columbia. The Commonwealth of Virginia can accurately predict that the effect of the proposed policy would be to close experienced and effective adoption agencies and simply harm children. Instead, the Commonwealth should find ways to support and encourage the remarkable work of private adoption agencies: the work of loving children.

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