I cannot support this regulation as written as it may have the effect of disenfranchising existing faith based child adoption and placement services and individuals of conscience who provide a significant portion of these LICENSED PRIVATE CHILD PLACING AGENCIES in the Commonwealth of Virginia.

The wording of this regulation is unacceptably vague as to what constitutes discrimination for classes other than those Federally recognized groups. This may result in competing protected class claims.

For this reason, Section 22VAC40-131-170 12.B of this regulation should be amended to only reflect the standard protected classes, specifically:

• Race - Federal: Civil Rights Act of 1964 and the Civil Rights Act of 1866
• Color - Federal: Civil Rights Act of 1964
• Religion - Federal: Civil Rights Act of 1964
• National origin - Federal: Civil Rights Act of 1964
• Age (40 and over) - Federal: Age Discrimination in Employment Act of 1967
• Sex - Federal: Equal Pay Act of 1963 & Civil Rights Act of 1964
• Familial status (Housing, cannot discriminate for having children, exception for senior housing)
• Disability status - Federal: Vocational Rehabilitation and Other Rehabilitation Services of 1973 & Americans with Disabilities Act of 1990
• Veteran status - Federal Vietnam Era Veterans Readjustment Assistance Act of 1974
• Genetic information - Federal: Genetic Information Nondiscrimination Act