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
Previous Comment     Next Comment     Back to List of Comments
4/1/11  9:40 pm
Commenter: Mark S.

Regarding protected classes in 22 VAC 40-131-170 12(B)

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:

CommentID: 17238