22VAC40-211-30 Background checks and health standards

D.  A tuberculosis test should be required instead of a screening in order to get a baseline.

22VAC40-211-40 Home study requirements

6.B A confidentiality form signed by the foster parents needs to be filed in the foster parent file, not the child’s file.  It is assumed that this would be a blanket form.  Requiring it to be placed in the child’s record creates an unnecessary administrative burden..

22VAC240-211-50 Approval period and documentation of approval

A.B Increasing the provider approval period from 24 months to 36 months is too risky.  The period should remain 24 months per the current standards.  Requiring monthly face to face visits by workers to children in their placement and increasing the provider approval period are incongruent.  A home should be recertified every two years in order to minimize risk to children and to document changes in the provider home.

22VAC40-211-60 Training

B.B  The standards should state a minimum number of in-service training hours for providers since the training can be accomplished in a variety of ways. It is recommended that providers be required to attend at least 8 hours of in-service training every year.

C.B The standards should require a minimum number of in-service training hours. We recommend a minimum of 8 hours per year.

22VAC40-211-70 Standards for the home of the provider

D. The standards should specify whether the phone needs to be a land line telephone or whether a digital phone or a cellular phone would suffice.  A land line is preferable.  If a parent has only a cellular phone, it will not be available to the people at home when the parent takes the phone out of the home.

F.B The maximum age for children to be allowed to share a bed should remain at the current standard of two years old.  The proposed standard of 16 months is too narrow.  Is there serious concern that children between the ages of 16 and 24 months will molest or abuse each other?  The proposed standards do not take into account siblings where it would be appropriate for them to continue to share a bed iin.

L. It is of great concern that the standards do not place any limits or guidelines on the number of children who can be placed in the home at the same time. Under the previous standards, there were limits on capacity depending on variables such as age of child, special needs of child, and if there were one or two parents in the home. It is recommended that the same capacity limits be included in the current standards for foster homes. By not including capacity limits, some agencies may overcrowd homes and place children in inappropriate living situations.  In addition, a variance to the standard can be requested by a locality when the standard needs to be exceeded.

22VAC40-211-100 Monitoring and re-approval of providers

A. This standard, requiring quarterly visits to the home of the provider to support and monitor performance and to provide quarterly documentation in the foster home file, is an UNFUNDED MANDATE and should be removed.  If the standard were instituted, our pool of 173 foster homes would require 1,211 additional instances of documentation in foster home files over a two year period (173 x 7 documentations, not counting the biannual recertification).  The proposed standard is unnecessary because social workers are already required to visit children in their foster homes on a monthly basis at which time they are reviewing performance and providing support.  Coordinating the scheduling and documentation of visits between our 50+ case carrying social workers and our foster home review staff would be extremely cumbersome.  In addition, the proposed standard does not indicate whether the agency must visit only families where a child is placed, or whether quarterly visits are required for all approved providers.

4.B A tuberculosis screening should not be required at time of  renewal.  It would be disruptive and harmful to children to have to remove them from homes where the screening had not taken place on time.  Also, there is a cost to the family associated with this requirement.