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  11:33 am
Commenter: Elaine Perricone

proposed regulations for private Licensed Child Placing Agencies

I write with regard to 22VAC 40-131-170 Part B.  While the VA state board of Social Services may have authority to repeal existing regulation and propose replacement regulations in regard to standards for licensed private child placing agencies, they do not have the right to infringe upon the free act of an individual to choose a religion.  There are many private agencies in VA.  In fact the regulation itself has pointed out that there are 77 such agencies that will be affected by these regulations.  Many are faith based and that is well known.  I think it likely that many birth mothers choose these agencies for the very reason that they wish for their child to be placed in such homes, i.e. faith based.  That is at least an option for them.  Banning such a choice under the guise of prohibiting discrimination of religion disregards a birth mother's wishes.  "Family status" is also stated.  I could not find that listed in the page of definitions within the regulations.  What is the meaning of this phrase? "Sexual orientation"...cannot a birth mother choose for her child to have a mother and a father for adoptive parents?  Furthermore, faith based private agencies, though regulated by the state, arise from the very beliefs that you wish to disregard by these regulations.  It is stated on page 1204 of Volume 27 issue 11 that "this regulatory action poses no disadvantages to the public or Commonwealth."  This is hardly the case.  If these regulations are accepted, it will ultimately force many private licensed child placing agencies to close their doors.  What will the state do then with all these children?

CommentID: 16539