Be careful of unintended consequences and unfunded mandates
22VAC40-211-20 A
If an applicant only chooses to provide only Foster Care Services and not Adoption, do they still have to meet the same requirements of a Resource Family? Will Kinship Care Families have to meet the same requirements? The proposed Standards do not address Emergency Approvals. Will Emergency Approvals still be an option and if so what will the procedures be for completing an Emergency Approval? Many of the LDSSs do not complete adoption home studies unless it is court ordered or it benefits a current foster child. People inquiring about adoption only are otherwise referred to Private Adoption Agencies. Will LDSS be obligated to complete an approval on an applicant only interested in adoption?
22VAC40-211-30 D
The change from requiring all adult members to all household members to submit to tuberculosis screening or test will increase the cost of approving resource families. Who is responsible for paying for the cost of the screenings? In addition there will be an extra burden for parents having to now get this done on their children. Will there be a standard physical form for resource parents to have completed that specifically addresses their mental or physical condition relative to taking care of a child? Currently, most physicians do not address this issue during a routine physical; therefore it may not be enough to simply get a copy of a current physical. Again, who is responsible for paying for the cost of the physical? Not all insurance companies will pay for this cost and even if they do, the resource family is likely to have a co-pay. These increase the amount of time it takes to approve a resource family
22VAC40-211-30 E
What offenses or how many points would make a resource parent ineligible? We need guidance on how to use the information we receive. If a resource family has in their home an 18-21 year old foster child, does that child have to comply with the same background and DMV checks?
22VAC40-211-40 B
The required paperwork should be submitted in its entirety before the burden to complete the home study falls to the department. There are many incidences where we receive a completed application from a prospective foster parent, but they never complete the fingerprinting requirements or never submit the tuberculosis screening.
22VAC40-211-40 C This will increase the amount of time required to approve a resource family and will increase worker hours in order to accommodate resource families. This will have social workers spending more time working in the evenings when families are typically all home at the same time. For small rural areas this can quickly add up to overtime for workers and a financial impact for localities.
22VAC40-211-40 F 4f What classifies as marital stability? What about cohabitating and homosexual couples? LDSS could use guidance on this issue.
22VAC40-211-40 F 6
Is it necessary to keep a copy of this form in the child’s file when it will already be in the provider’s file? If you make this form child specific then you would have to get providers to sign this form for each child in their care. It makes more sense to have the provider sign a blanket acknowledgement and keep it in the provider file.
I believe that this proposed home study process (although positive in some aspects) will add considerable time to the approval process and social worker hours. Many LDSSs in small rural areas do not have staff available or specifically designated to approve resource homes. How will these LDSSs be able to meet these new standards without money for additional positions? If we continue to lengthen the time it takes to approve resource families, then we run the risk of frustrating our applicants and losing potential resource families. What about existing families, will they be grandfathered in or must they be compliant right away or can it wait until their reapproval time?
22VAC40-211-50 B3
"recommended"--does this mean a social worker can place more children or children of age or gender different than what is written?
22VAC40-211-60 A
Although we like the idea of requiring Pre-Service Training, we are concerned that requiring this many core competencies will hinder the approval process. For reasons previously stated, LDSS in rural areas do not have the resources to meet this standard unless the state intends to provide money for training and for positions to provide the training. Such a lengthy Pre-Service Training may deter potential resource families.
22VAC40-211-60 B2
Again we approve of requiring annual training; however additional money is needed for training and positions in order for the LDSS to comply with these standards.
22VAC40-211-70 The following issues are not addressed but are in the current regs:
Drinking water shall be available at all times.
The provider shall have first aid supplies easily accessible in case of accident.
The out-of-home provider shall keep medicines and drugs separate from food except those items that must be refrigerated.
Sufficient space and equipment for food preparation, service and proper storage.
The provider shall immediately report any suspected abuse, neglect, or exploitation of any adult or child in care to the agency.
The provider shall permit an inspection of the home’s private water supply and sewage disposal system by the local Health Department if conditions indicate a need for approval and the agency requests it.
22VAC40-211-70 5F Even same sex siblings? This seems excessive
22VAC40-211-70 I4
Again what are the state and local ordinances? What will be considered as verification of provider compliance? What about exotic pets?
22VAC40-211-70 I6
If a provider does not own an ABC class fire extinguisher, will there be money available to purchase them for the family?
22VAC40-211-70 M
This sounds like a pretty extensive plan. Will we be given an example of a plan that would meet these requirements to use as a guide? Again I believe that the extensiveness of this plan will lengthen the approval process.
Will the identified adult have to complete the same background checks?
22VAC40-211-80 A
Then cohabitating and/or homosexual couples should not be barred (as they are in some localities) from becoming resource families
22VAC40-211-100 A
This requirement will add significantly to worker hours. Can the monitoring be done by either the staff person who approved the provider or a staff person who has placed clients with the provider as stated in past standards and regulations? Does this apply to all providers or just those that have current placements? Although a great idea, this will have significant finanical impact to the localities.
22VAC40-211-100 B 3 Should this be "national" instead of "state"
22VAC40-211-100 B 4
We currently only do this step at approval. Why is it necessary to complete this step at re-approval? All household members, even children? This requirement will add time and cost to the re-approval process. Who pays for this?
22VAC40-211-100 The following are not addressed:
A Compliance Form for Agency Approved Provider should be completed for each provider.
The provider must receive written notification regarding action on the application or at renewal. A Certificate is adequate written notice for providers who receive one.
