It is a very good move to separate the standards and regulations for the various provider types!

With regards to the regulation being developed for the foster, resource, and adoptive families, I suggest stating in the regulation that a narrative home study for foster as well as adoptive homes has to be completed. From this broad statement in regulation, the policy could then address the standard information that is required for the homestudy. Many agencies currently only utilize the compliance checklist and background checks for foster homes. The narrative home study provides information that can help agencies make better matches thus hopefully reducing movements in foster care and it will be in line with concurrent planning and adoption goals.

Will regualtion address whether families caring for severely disabled/medically unstable/extremely behaviorally disordered children have to meet stricter in-service training requirements? It seems that after placement occurrs we often discover that children have problems previously unknown to the agency and it would be best to require the family, when they are invested in keeping the child, participate in more training -- perhaps child specific.

A minimum number of hours for pre-service should be mandated as well as a minimum number for in-service. By simply saying that training will be required it allows for too great a variation between agencies -- even with a minimum number of hours there will be variation but at least the agencies who provide very minimal training will be doing so with some type of consistency. Just saying that the training will be competency based dos not ensure that any appropriate amount of time will be spent on the training.

If regulation is going to state that training has to be competency based it needs to clealry define what that means.